Assuritivity Consulting Privacy Policy  

(Last updated: 31 March 2022)

Table of Contents

• Introduction
• Grounds for data collection
• What information do we collect?
• How do we receive information about you?
• How do we use information about you?
• User Rights
• Retention
• Cookies
• Third-party collection of information
• How do we safeguard your information?
• Transfer of data outside the EEA
• Advertisements
• Marketing
• Corporate transaction
• Minors
• Updates or amendments to this Privacy Policy
• How to contact us

Assuritivity Consulting (referred to as "we", "us", "our" or "the Company" in this Privacy Policy) understands that your privacy is important and that you care about how your personal data is used and shared online.

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.assuritivity.com ("Site"), when you contact us directly, or when you have given us your consent, or otherwise share personal information with us (collectively: "Users"). Any personal data we do collect will only be used as permitted by applicable data protection legislation.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

By providing us with your data, you warrant to us that you are over 13 years of age (see also the section “Minors”).

Assuritivity Consulting Ltd is the data controller and we are responsible for your personal data.

We may change this policy from time to time by updating this page. You should check this page occasionally to ensure that you are happy with any changes. This policy is subject to any additional terms of disclaimers or other contractual terms you have entered into with us such as client privacy statements or notices, and any applicable mandatory laws and regulations.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at WebsitePrivacyPolicy@Assuritivity.com.

Personal data and personal information (hereinafter "Personal Information") means any information capable of identifying an individual or may potentially allow your identification through reasonable means. It does not include anonymized data.

Processing of your personal information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with any legal and financial regulatory obligations to which we may be subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

We do not collect any Sensitive Data about you. Sensitive Data refers to data that 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. We do not collect any information about criminal convictions and offences.

We collect and process the following types of data and information from Users: 

• Non-personal Information: unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site. We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time) in order to enhance the functionality of our Site. We may also collect information about your activity on the Site (e.g. pages viewed, online browsing, clicks, actions).

• Personal Information: individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:
• Device Information: we collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

• Registration information: When you register with our Site, you will be asked to provide us with certain details such as: full name; email or physical address, phone number and other information. 

• Communication Data: includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication.
• We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims.
• Our lawful ground for this processing is our legitimate interests which, in this case, are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

• Customer Data: includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
• We process this data for making services available or providing services to you, where we need to perform under a contract into which we have entered with you and to keep records of such transactions, for on-going administrative purposes, where we need to comply with a legal obligation, for being able to contact individuals about business partners’ promotions, where you’ve provided us with consent to contact you directly about events.
• Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, and to allow us to understand our customers and provide the highest levels of service.

• Associate Data: includes data relating to the supply of services such as your name, title, company name, billing address, email address, phone number, contact details, payment details, professional career history, and any additional information included in a CV.
• We process this data to assess the competency of the associate and their suitability for the supply of services to us and/or our clients, decide whether to include their CV in a proposal to a client, where you need to perform under a contract you have entered into with us and to keep records of such transactions, for on-going administrative purposes, where we need to comply with a legal obligation, for being able to contact individuals about promotions and events, where you’ve provided us with consent to contact you directly.
• Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, and to allow us to understand our associates suitability for roles and provide the highest levels of service.

• Technical Data: includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.
• We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. 
• Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.



• Marketing Data: includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.
• We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. 
• Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We may use the information for the following, our lawful ground for this processing of which is legitimate interests, which is to grow our business:

• Communicating with you: E.g.:
• To deliver relevant website content.
• To send you notices regarding our services.
• To provide you with technical information and responding to any customer service issue you may have.
• To keep you informed about our latest updates and services.
• To serve you advertisements when you use our Site (see more under "Advertisements"), and to measure or understand the effectiveness of the advertising we serve you. 
• To market our websites and products (see more under "Marketing"); 
• To measure or understand the effectiveness of the advertising we serve you.
• For statistical and analytical purposes, intended to improve the Site or services.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors. E.g.:

• Professional advisers including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our Site.
• Service providers who provide IT and system administration services.
• Providing you with our services, including providing a personalized display of our Site.
• Storing and processing such information on our behalf.
• Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us re-target any of our users.
• Providing you with marketing offers and promotional materials related to our Site and services. 
• Performing research, technical diagnostics or analytics.

We require all third parties to whom we transfer your data to respect the security of your Personal Information and to treat it in accordance with the law. We only allow such third parties to process your Personal Information for specified purposes and in accordance with our instructions.

We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to:

• Comply with any applicable law, regulation, legal process or governmental request;
• Enforce our policies (including our Agreement), including investigations of potential violations thereof;
• Investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
• Establish or exercise our rights to defend against legal claims;
• Prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
• For the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

As a User, you have the following rights, which can also be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

You may request the: 

• Right to be informed: receive confirmation as to whether or not personal information concerning you is being processed.
• Right of access:
• Access your stored personal information, together with supplementary information. 
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
• Right to rectification: request rectification of your personal information that is in our control.
• Right to erasure: request erasure of your personal information. 
• Right to restrict processing: request to restrict processing of your personal information by us.
• Right to data portability: for any information you “have provided to a controller [us] in a structured, commonly used and machine readable format”.
• Right to object: object to the processing of personal information by us. 
• Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the above rights or receive more information, please contact us at: WebsitePrivacyPolicy.DataProtection@Assuritivity.com.

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 or refuse to comply with your request in these circumstances.

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.

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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

We will only retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies.

Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity.

Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

We and our trusted partners may use cookies and other technologies in our related services, including when you visit our Site or access our services. We are trying to phase these out completely as we also dislike cookies; however, we are limited in our ability to make this happen while still providing our services to a good quality. 

You are not obliged to accept 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 this website may become inaccessible or not function properly, and your online experience may be limited.

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes, which include:

• Allowing you to navigate between pages efficiently.
• Enabling automatic activation of certain features.
• Remembering your preferences.
• Making the interaction between you and our Services quicker and easier.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences.

Cookies are also used to help ensure that the advertisements you may see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site may use the following types of cookies:

• Session cookies: which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed. 
• Persistent cookies: which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 
• Third-party cookies: which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyze our web access.

Cookies can also be categorized as follows:

• Strictly necessary cookies: which are cookies that are required for the operation of our website. Without the use of these cookies most parts of our website would not function, and services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Analytical/performance cookies: which allow us to recognize 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 and identify any areas that return errors or may need maintenance. All information these cookies collect is aggregated and is only used to improve how our website works.
• Functionality cookies: which allow the website to remember choices and changes you make when using our site, enabling us to personalize and enhance our content for you. For example, your choice of any list view preferences; being able to provide you with news or updates relevant to the services you use. 
• Targeting cookies: which record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, which pages they visit, when they do so etc.. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.

Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party to whom you choose to disclose information. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties to whom we may disclose information as set out in this Privacy Policy. 

For example, this website may include links to third-party websites, plug-ins or 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.

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you, either due to your consent or our legitimate interests (namely to grow our business). 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:

• you made a purchase or asked for information from us about our goods or services or
• you agreed to receive marketing communications

and, in each case, you have not opted out of receiving such communications since.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

To respect your right to privacy, within such marketing materials, we provide you with the means to opt out of receiving further marketing offers from us; or you can email us at WebsitePrivacyPolicy.Marketing@Assuritivity.com at any time. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. 

Please note that, even if you have unsubscribed or opted out from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include:

• Customer service announcements.
• Administrative notices.
• Personal data provided as a result of other transactions, such as purchases, warranty registrations etc..

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at WebsitePrivacyPolicy@Assuritivity.com.

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section at the top of this policy. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at WebsitePrivacyPolicy@Assuritivity.com.