Introduction
Welcome to Cambridge Intelligence’s privacy policy.
Cambridge Intelligence respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- Important information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Glossary
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Cambridge Intelligence collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, download a white paper report, purchase or request a trial of our software and services or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. This privacy policy supplements the other privacy policies and notices and is not intended to override them.
Controller
Cambridge Intelligence Limited is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy). Our Representative in the European Union according to Art. 27 UK GDPR is Rickert Rechtsanwaltsgesellschaft mbH, Colmantstraße 15, 53115 Bonn, Germany, email address: [email protected].
We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
Contact details
Our full details are:
| Full name of legal entity: | Cambridge Intelligence Limited |
| Name or title of DPM: | Elisa Casagrande, Legal Counsel |
| Email address: | [email protected] |
| Postal address: | 6-8 Hills Road, Cambridge, CB2 1JP, UK |
| Telephone number: | +44 (0)1223 362000 |
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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last reviewed on 27 June 2024. Historic versions can be obtained by contacting us.
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.
Third-party links
This website may include links to third-party websites, plug-ins and 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. 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 different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name and job title.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, URL, referrer, device and browser characteristics (User Agent), timestamp, time zone setting and location, operating system, device and platform and other technology on the devices you use to access this website.
- Transaction Data includes details about payments from and to you and other details of software and services you have purchased from us.
- Profile Data includes feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Some of our customers may choose to pay for our software and services by credit card. We do not store, process or collect credit card information as this is not submitted to us. Rather, we use a PCI compliant payment vendor to ensure customers’ credit card information is processed securely by them and according to appropriate regulation.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and/or the business you represent, and there is a failure to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you and/or the business you represent with software and services). In this case, we may have to cancel any provision of software and/service that you and/or the business you represent has with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- 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:
- request a trial of our software;
- request information about our software and services;
- begin an evaluation of our products or become a customer;
- subscribe to our newsletter;
- request marketing to be sent to you;
- download a white paper report;
- enter a competition or survey;
- sign up to one of our webinars or events;
- provide us with your business card; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website or marketing newsletters/emails or individual sales emails, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, tracking pixels, personalised tracking URLs, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data and Usage Data from the following parties:
- analytics and marketing automation providers such as Google Analytics, Matomo and HubSpot;
- advertising networks such as Google Adwords or Microsoft Advertising;
- Contact and Transaction Data from technical, payment and other third party services such as Squareup.
- Identity and Contact Data from publicly available sources such as Companies House.
- Identity and Contact Data from our wholly owned subsidiary company, Cambridge Intelligence Inc.
- Publicly visible identity and Contact Data from the following sites: Twitter, YouTube, LinkedIn and Apollo.io.
- Technical Data and Usage Data from the following parties:
4. 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 in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you and/or the business you represent.
- Where it is necessary to conduct our business and pursue our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
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 register you and/or the business you represent as a new contact or customer |
(a) Identity (b) Contact |
(a) Performance of a contract (b) Necessary for our legitimate interests (for running our business) |
|
To process our transactions with you on behalf of the business you represent which will include: (a) Managing payments, fees and charges (b) Collecting and recover money owed to us |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract (b) Necessary for our legitimate interests (to receive payment and recover debts due to us) |
|
To manage our relationship with you on your own behalf and/or on behalf of the business you represent which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey on your own behalf and/or on behalf of the business you represent |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and/or the business you represent and measure or understand the effectiveness of the advertising we serve to you and/or the business you represent |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about our software and services that may be of interest to you and/or the business you represent |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. At the bottom of every marketing email, newsletter, product update or event invite you will find a link to your subscriber preference centre. Here you can view and make decisions about your personal data use, including an option to opt-out of all marketing communications.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you and/or the business you represent may want or need, or what may be of interest to you and/or the business you represent. This is how we decide which software and services and offers may be relevant for you and/or the business you represent (we call this marketing).
You will receive marketing communications from us if (i) you have requested information from us on your own behalf and/or on behalf of the business you represent or (ii) you represent a business that has purchased our software and services or (iii) if you provided us with your details when you entered a competition or registered for a promotion on your own behalf and/or on behalf of the business you represent and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will not share your personal data with any company outside the Cambridge Intelligence group (being Cambridge Intelligence Ltd and our wholly owned subsidiary, Cambridge Intelligence Inc) for marketing purposes unless we have received your consent to us so doing.
Opting out
You can ask us or third parties 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.
If you opt out of receiving these marketing messages, you will still receive services-related communications that are essential for administration or customer service purposes relating to a software/service purchase by you and/or the business you represent, product/service experience or other transactions made by you and/or the business you represent.
Cookies and similar technologies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies we use, please see our Cookie Policy.
You can deactivate tracking pixels in emails by disabling image autoloading in your email client.
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 wish to get 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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- 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 policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data with Cambridge Intelligence Inc, our wholly owned subsidiary based in the USA. This will involve transferring your data outside the UK. We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, 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 by the UK to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contractual terms approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw 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, starting from the day of receipt. If your request is complex or you make more than one, the response time may be a maximum of three months, starting from the day of receipt. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you and/or the business you represent the best service and software 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
Internal Third Parties
Cambridge Intelligence Inc, our wholly-owned subsidiary, acting as a processor and which is based in the USA and undertakes business support including sales on behalf of the Company.
External Third Parties
Service providers acting as processors predominantly based in the USA who provide IT hosting services to help us operate our business and our website or administer activities on our behalf, including Google Suite, Google Cloud, Microsoft Office 365, Trello, SalesForce, Slack, AHA, Amazon Web Services, Xero (including Expensify), Flowrev, Calendly, SendGrid, Docusign, DataDog, Zoom and Livestorm.
Service providers acting as processors based in the UK, EU and/or the USA who provide a range of services to us to help us operate our business, including Squareup which acts as our PCI compliant payment vendor for customers which wish to make payments to us by credit card, HubSpot which provides marketing automation services, a number of debt collection agencies which collect debts owed to us from our customers, and ‘apilayer’, which provides data verification and lookup APIs.
Service providers acting as processors based in the UK and/or the USA who provide accounting, tax, financial and management consulting services.
Our webinar and event partners whose details are provided at the time and in relation to which you provide your consent.
YOUR LEGAL RIGHTS
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 data’s accuracy; (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 software or services to you and/or the business you represent. 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 at the following address: [email protected].
RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would encourage you to contact us first so we can deal with your concerns.