Forty Eight Point One

48.1 Privacy Policy

PRIVACY NOTICE

1. Introduction
48.1 respects your privacy and is committed to protecting your personal data. This privacy notice is for:
• Our clients’ staff Our potential clients’ staff Our suppliers’ staff Our potential suppliers’ staff
• Job applicants Users of our website Our freelancers Individuals who receive our marketing communications

This privacy notice will inform you as to how we look after your personal data, what your privacy rights are and how the law protects you.

2. Important information and who we are

Please read this privacy notice
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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.

Controller
48.1 is the controller and responsible for your personal data (collectively referred to as “48.1”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the data privacy manager using the details set out below.

Contact details
Full name of legal entity: Forty Eight Point One Limited.
Name or title of data privacy manager: James Sandrini.
Email address: james@fortyeight.one
Postal address: 81 Rivington Street, London EC2A 3AY
Telephone number: +44 (0) 20 8088 0481.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 31 January 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. The data we collect about 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).

We may collect, use, store and transfer the following different kinds of personal data about you:
• Identity Data includes first name and last name.
• Contact Data includes home address, business/personal email address and business/personal telephone numbers.
• Background Data for example your employment and education history data and your interests as they may appear on a CV or other media (job applicants only).

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (see above), to help us analyse how users use our site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. We have activated IP-anonymisation, which will anonymise your IP address by cutting it short. In most cases this procedure will be carried out within the area of the European Union and other parties to the European Economic Area Agreement. In exceptional cases the whole IP address will be first transferred to a Google server in the U.S. and then shortened there. Google will use the information on behalf of 48.1 for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing us with other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of these cookies via the settings in your browser. You can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en

4. How is your personal data collected?

Direct interactions 
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you enquire about our services.
If you are a job applicant, you may provide us with a copy of your CV containing Background Data when you apply for a position with us.

Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
Identity Data and Contact Data: from recruitment agents, our staff or our other contacts and from searches on websites where you have added this data (for example, Linkedin) (job applicants only) or from internet searches.

Background Data: from recruitment agents, our staff or our other contacts, from internet searches, searches on websites where you have added this data (for example, Linkedin) (job applicants only).

5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data 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.

Here are some examples of us using your personal data where it is necessary for our legitimate interests: to reply to an enquiry that you have sent us, to provide our services to your business, to receive goods or services from your business or to consider your job application. We will also use your personal data to send you information about our services.

See section 11 below to find out more about the types of lawful basis that we will rely on to process your personal data.

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 are using your data. Please contact us if you need details about the specific legal ground we are relying 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 provide our services to your business
(a) Identity
(b) Contact
Necessary for our legitimate interests (to supply our services to our clients)

To enquire whether your business would be interested in receiving our services
(a) Identity
(b) Contact
Necessary for our legitimate interests (to find clients to supply our services to)

To receive good or services from your business
(a) Identity
(b) Contact
Necessary for our legitimate interests (to receive goods or services from our suppliers)

To consider your business’ offer to supply goods or services to us
(a) Identity
(b) Contact
Necessary for our legitimate interests (to identify suppliers to receive goods or services from)

To administer and protect our business (e.g. troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security)

To make suggestions and recommendations to you about services that may be of interest to you
(a) Identity
(b) Contact
Necessary for our legitimate interests (to develop our services and grow our business)

To consider your application for a job with us
(a) Identity
(b) Contact
(c) Background Necessary for our legitimate interests (to recruit for our business)

Marketing 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Service offers from us 
We may use your personal 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 services may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or if we are legally permitted to make unsolicited contact with you. We will not contact you if you have opted out of receiving that marketing.

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

Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies
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 our website may become inaccessible or not function properly.

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 would like 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.

6. Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in section 5 above.
• External Third Parties as set out in section 11 below
• 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.

All third parties are required to respect the security of your personal data and to treat it in accordance with the law.

7. International transfers
We do not transfer your personal data outside the European Economic Area (EEA) other than as set out below.

Like most businesses we use software to support our operations. For example, we use Google as one of our email providers. Your personal data may therefore be transferred out of the EEA because Google and other major players in the software industry store some of their data in the U.S.

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.
• 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.
• Where we use providers based in the U.S., we may, instead of using model contracts approved by the European Commission, transfer data to them if they are listed on the EU-U.S. Privacy Shield List.

What is the EU-U.S. Privacy Shield List?
The EU-U.S. Privacy Shield Framework was designed by the U.S. Department of Commerce and the European Commission to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. On July 12, 2016, the European Commission deemed the EU-U.S. Privacy Shield Framework adequate to enable data transfers under EU law.
The Privacy Shield program, which is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce, enables U.S.-based organisations to join the EU-U.S. Privacy Shield Framework in order to benefit from the EU’s adequacy determinations. To join the EU-U.S. Privacy Shield Framework, a U.S.-based organisation is required to self-certify to the U.S. Department of Commerce and publicly commit to comply with the Framework’s requirements.

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

8. Data security
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.

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.

9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Details of retention periods for different aspects of your personal data are available in our data retention policy which you can request by contacting us. We will retain the personal data of job applicants for two years from the time that we collect it.

In some circumstances you can ask us to delete your data: see “request erasure” in section 10 below for further information.

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.

10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

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.

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.

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 continuing 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.

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 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.

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 accuracy of the data; (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.

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.

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.

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

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

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.

11. Glossary

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.

Comply 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.

THIRD PARTIES

External Third Parties
• Service providers who provide IT and system delivery/administration services.
• Professional advisers who provide, for example, accountancy and legal services.
• Regulators and other authorities who may require reporting of processing activities in certain circumstances.

 

Forty Eight Point One Ltd
The Office Group
81 Rivington St
London
EC2A 3AY

Company Reg: 10484397