Privacy Policy

1. Introduction

It is important to Gimlet Associates Ltd that our governance processes remain trusted by all who come into contact with our organisation.  This trust extends from the way that we treat individuals’ privacy to our approach regarding individuals’ rights and freedoms in relation to their Personal Data.

In order to operate our business, we need to collect Personal Data from those who interact with us when obtaining services from us, accessing our website, engaging with us during business development activities, working with us as contractors or providing products or services to us during our day-to-day activities.  We are committed to complying with Our legal obligations for the protection of Personal Data in all respects and are registered with the Information Commissioner for the purposes of Data Protection, registration number ZA274006. 

Our Privacy Policy below gives information on how we collect Personal Data. Please read our Privacy Policy carefully.

2. Definitions

In this Policy:

• “We”, “Us” and “Our” means Gimlet Associates Ltd;

• “You” and “Your” means any third party that is not employed by Gimlet Associates Ltd;

• “Personal Data” means any information that relates to You or any identified or identifiable individual;

• “Website” means our website at www.gimletassociates.co.uk;

• “Third Parties” includes third-party service providers and other entities which support our service provisions;

• “Data Protection Legislation” means General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other UK regulations and legislation as amended or updated from time to time.

In using these definitions, this Privacy Policy describes how We may treat your Personal Data in accordance with Data Protection Legislation.

3. Management Principles

Gimlet Associates Limited is a business consultancy firm registered in England and Wales as a limited company (registration number: 09101936). Our registered office is at Moyola House, 31 Hawthorne Grove, York, YO31 7YA. 

For Data Protection Legislation purposes and within this Policy, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use Your Personal Data. We are required under the Data Protection Legislation to notify You of the information contained in this Privacy Policy.

4. Collecting Personal Data

We may collect Personal Data during a range of interactions, for example, when:

• You contact Us by email, telephone, post or social media (e.g. when enquiring about Our services);

• You exchange contact details with Us, for example at events or meetings;

• You request a proposal for Our services from Us;

• You engage Us to provide Our services and during the provision of Our services; or

• From third parties and/or publicly available resources (for example from Your employer, Companies House or publicly available websites such as LinkedIn).

5. The kind of information we may hold about You

The information we hold about You may include Personal Data as well as other information:

• Personal details (for example Your name and/or address);

• Details of contact We have had with You in relation to the provision or the proposed provision of Our services;

• Details of any services You have received from Us;

• Our correspondence and communications with You;

• Information about any complaints and enquiries You make to Us;

• Information from research, surveys, and marketing activities;

• Information from other sources, such as publicly available information or information provided by Your employer;

• Information about Your use of Our Website.

It is important that the Personal Data We hold about You is accurate. Should circumstances change which affect Your Personal Data please notify Us of the changes We need to make in relation to the Personal Data We hold about You by contacting Us.

6. What legal basis do We have for processing Your Personal Data?

We may process Your Personal Data in line with Data Protection Legislation for any of the following reasons as appropriate to the activity being undertaken:

• For the performance of Our contract with You or Your employer and to comply with Our legal obligations.

• For the performance of Our contract with Our clients. This may include processing Your Personal Data where You are an employee, subcontractor, supplier or customer of Our client.

• For the purposes of Our own legitimate interests provided that those interests do not override any of Your own interests, rights and freedoms which require the protection of Personal Data. This includes processing for marketing, business development, statistical and management purposes.

• For certain additional purposes with Your consent.  Where Your consent is required for the processing of Your Personal Data then You have the right to withdraw Your consent to processing for such specific purposes.

Please note that We may process Your Personal Data for more than one lawful basis depending on the specific purpose for which We are using Your Personal Data.

7. Situations in which we use Your Personal Data

We may use Your Personal Data to:

• Carry out Our obligations arising from any agreements entered into between You or Your employer and Us (which will usually be for the provision of Our services);

• Carry out Our obligations arising from any agreements entered into between Our clients and Us (which will usually be for the provision of Our services) where You may be a subcontractor, supplier or customer of Our client;

• Provide You with information related to Our services and activities that You request from Us or which we feel may interest You provided You have consented to be contacted for such purposes;

• Seek Your opinions or feedback on the services We provide; and

• Notify You about any changes to Our services.

In some circumstances We may anonymise or pseudonymise the Personal Data so that it cannot be associated with You, in which case We may use it without further notice to You.

If You refuse to provide Us with certain information when requested, We may not be able to perform the contract We have entered into with You as to do so would make Us unable to comply with Our legal or regulatory obligations.

We may also process Your Personal Data without Your knowledge or consent, in accordance with this notice, where We are legally required or permitted to do so.

8. Data sharing

We will treat all Personal Data confidentially and will share it with or disclose it to Third parties only:

• Where it is necessary to administer the relationship between Us;

• Where We are required by law; or 

• Where We have another legitimate interest in doing so.

8a. Which Third Party service providers may process Your Personal Data?

The following activities are carried out by Third Party service providers:

• IT and cloud services;

• Professional advisory services;

• Administration services;

• Marketing services; and

• Banking services.

We may share Your Personal Data with other Third Parties for example in the context of the possible sale or restructuring of Our business. We may also need to share Your Personal Data with a regulator or to otherwise comply with the law.

8b. How will Your Personal Data be safeguarded if We share it with Third Parties?

All of our Third Party service providers are required to take commercially reasonable and appropriate security measures to protect Your Personal Data. We only permit our Third Party service providers to process Your Personal Data for specified purposes and in accordance with their contractual responsibilities.

9. Transferring Personal Data outside the European Economic Area (EEA)

Personal Data which We collect from You may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). This could occur if Our servers are located in a country outside the EEA or one of Our service providers is situated in a country outside the EEA.  These countries may not have data protection laws equivalent to those in force in the EEA.

If We transfer data outside the EEA in this way, We will take steps with the aim of ensuring that Your privacy rights continue to be protected as outlined in this Privacy Policy.  By engaging with Us and continuing to use our services You agree to such cross-border transfers of data.

10. Data Security

We have put in place commercially reasonable and 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 restrict 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.  They are required to comply with Our Privacy Policy and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected data security breach and these include:

• Closing down the identified security breach;

• Identifying what data may have been compromised;

• Informing relevant individuals / regulators where this is legally required; and

• Taking steps to avoid future security breaches.

11. Data Retention

We will only retain Your Personal Data for as long as is reasonably necessary to fulfill the purposes for which it is collected.  When assessing what retention period is appropriate for Your Personal Data, we will consider:

• The requirements of Our business and the services provided;

• Any statutory or legal obligations;

• The purposes for which We originally collected the Personal Data;

• The lawful grounds on which we based our processing;

• The types of Personal Data We have collected;

• The amount and categories of Your Personal Data; and

• Whether the purpose of the processing could reasonably be fulfilled by other means.

12. Change of purpose

Where We need to use Your Personal Data for another reason other than for the purpose for which We collected it We will only use Your Personal Data where that reason is compatible with the original purpose.

Should it be necessary to use Your Personal Data for a new purpose, We will notify You and communicate the legal basis which allows Us to do so before starting any new processing.

13. Use of our Website www.gimletassociates.co.uk

This Privacy Policy extends to Your use of Our Website. It does not extend to any websites that may be accessed from Our Website and You are advised to read the privacy policy or notice of other websites prior to using them. 

In line with Our business principles, We endeavour to do Our best to protect Your Personal Data.  However, transmission of information over the internet is not entirely secure and is done at Your own risk.  We cannot ensure the security of Your Personal Data transmitted to the Website.

13a. Cookies

Our Website may place and access certain Cookies on Your computer.  These Cookies collect information in an anonymous form.  Some of the Cookies We use are essential for the Website to work.  We also use some non-essential Cookies to collect information for making reports and to help Us improve the Website.

All Cookies used by Our Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on Your computer, You will be presented with a message bar requesting Your consent to set those Cookies. By giving Your consent to the placing of Cookies You are enabling Us to provide a better experience and service to You.  You may if You wish deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

Our Website may place the following Cookies:

• Strictly necessary Cookies - These are cookies that are required for the operation of our website.

• Analytical / performance Cookies - These allow Us to recognise and count the number of visitors and to see how visitors move around Our Website when they are using it.  This helps Us to improve the way Our Website works, for example, by ensuring that users are finding what they are looking for easily.  Analytical Cookies that are collected automatically also include:

  • IP address;

  • Web browser type (e.g. Chrome or Internet Explorer);

  • Device type;

  • Source of visit (e.g. from named search engine, directly accessed or email link);

  • Search engine keywords used;

  • Operating system (e.g. Windows, Android, Mac or iOS);

  • Geographic location.

You can choose to enable or disable Cookies in Your internet browser.  By default, most internet browsers accept Cookies but this can be changed.  For further details, please consult the help menu in Your internet browser.

You can choose to delete Cookies at any time; however You may lose any information that enables You to access the Website more quickly and efficiently including, but not limited to, personal settings.

It is recommended that You ensure that Your internet browser is up-to-date and that You consult the help and guidance provided by the developer of Your internet browser if You are unsure about adjusting Your privacy settings.

Please read Our Website Terms of Use statement for further information on acceptable terms of use when accessing Our Website.

14. Your rights

Under certain circumstances by law You have the right to:

• Request access to Your Personal Data to enable You to receive details of the Personal Data we hold about You and to check that we are processing it lawfully;

• Request correction of the Personal Data that We hold about You;

• Object or opt out where We are processing Your personal information for direct marketing purposes.

• 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 basis.

• Request Us to delete or remove Your Personal Data where there is no good reason for Us to continue to process it or where You have exercised Your right to object to processing.

• Request the restriction of processing of Your Personal Data. This enables You to ask Us to suspend the processing of Personal Data about You, for example if You want Us to establish its accuracy or the reason for processing it.

If You want to exercise any of these rights, please email Us

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access the information (or to exercise any of Your other rights). This ensures your Personal Data is not disclosed to another person who has no rights to your Personal Data.

You will not have to pay a fee to exercise any of these rights; however We may charge a reasonable fee or refuse to comply if Your request for access is clearly unfounded or excessive.

14a. Right to withdraw consent

In the limited circumstances where You may have provided Your consent to the collection, processing and transfer of Your Personal Data for a specific purpose, You have the right to withdraw Your consent for that specific processing at any time. To withdraw Your consent, please email Us.

Once we have received notification that You have withdrawn Your consent We will no longer process Your Personal Data for the purpose / purposes You originally agreed to unless We are required to do so in law.

14b. Right to lodge a complaint

You have the right to make a complaint to the Information Commissioner’s Office (ICO) about any data protection issue.  Further information can be found at: https://ico.org.uk/concerns

15. Changes to Privacy Policy

Any changes We may make to our Privacy Policy will be provided to You by being updated on Our Website.

This privacy notice was last updated on 19th September 2018.

16. Further information and contact

If You have any questions regarding Our Privacy Policy or how Your Personal Data is handled by Us, please contact Us.