Privacy Policy

Information About Us

• Combined Intelligence Ltd
• A limited company registered in England under company number 12346017
• Registered address: 130 Old Street, London, England, EC1V 9BD
• VAT number: 340850615
• Data Protection Officer: Dr Steven Sheppard
• Email address: info@combined-intelligence.co.uk
• Telephone number: +44 (0)207 101 3217
• Postal address: 130 Old Street, London, England, EC1V 9BD

What Does This Notice/Policy Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out below.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details below.
• The right to access the personal data we hold about you. Learn more below.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the contact details below.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the contact details below to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided below.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. we would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details below.

What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, any personal data relating to children and data relating to criminal convictions and/or offences.

Data Collected	How we Collect the Data
Identity information including name and title.	Via direct engagement, via our website or through publicly accessible internet sources (such as LinkedIn, your organisation’s website or social media presence).
Business information including business name, job title and profession.	Via direct engagement, via our website or through publicly accessible internet sources (such as LinkedIn, your organisation’s website or social media presence).
Business contact information including email address, telephone numbers and business contact addresses.	Via direct engagement, via our website or through publicly accessible internet sources (such as LinkedIn, your organisation’s website or social media presence).
Data from third parties including business, contact and profile information.	As available from business social media sites (e.g. LinkedIn) and other publicly accessible websites (such as Companies House).
Subscription information.	Subscription status as registered through our company website (for our Insights emails).

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What we Do	What Data we Use	our Lawful Basis
Administering our business.	Business, contact and contractual information.	To enable us to contract or partner with you.
Supplying our services to you.	Business, contact and contractual information.	To enable us to supply our services to you.
Managing payments for our services.	Business, contact and contractual information.	To enable you to pay us for our services.
Communicating with you.	Contact information.	To enable us to communicate with you.
Supplying you with information by email that you have opted-in-to (you may opt-out at any time using the unsubscribe links within the emails).	Contact and subscription information.	Providing relevant information that you have subscribed to.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the contact details below.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long we Keep It
Identity information including name and title.	Until requested to be removed or when we become aware that it is either no longer correct or relevant for the original reason it was collected.
Business information including business name, job title and profession.
Business contact information including email address, telephone numbers and business contact addresses.
Data from third parties including business, contact and profile information.
Subscription information.	While you remain subscribed and for a period of up to 6 months after cancelling your subscription.

How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

• If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
• In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
• We may sometimes sub-contract work to third parties to supply products and/or services. The names of these third parties will be discussed and agreed with you in advance.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in contact details below.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

• Email address: info@combined-intelligence.co.uk
• Telephone number: +44 (0)207 101 3217
• Postal Address: 130 Old Street, London, EC1V 9BD, England

Changes to this Privacy Notice

We may change this Privacy Policy/Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available via our website. This Privacy Policy/Notice was last updated on 18/10/2021.