1.1 This privacy notice (Privacy Notice) sets out the ways in which we, AKJ Associates Ltd (we, us, our, AKJ), collect and use your personal data (your personal information) in connection with our business. It also explains what rights you have to access or change your personal data.
1.2 Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 18.
2. ABOUT US
2.1 We are a company registered in England under company number 03866759, with our registered address as set out below.
2.2 You can contact us as follows:
FAO: Helen Birkett, Operations Director
Address: 27 John Street, London, WC1N 2BX, UK
3. INFORMATION WE MAY COLLECT ABOUT YOU
3.1 Information that you provide to us.
3.1.1 We may collect any information that you provide to us when you:
(a) make an enquiry, provide feedback or make a complaint over the phone, by email or on our website;
(b) submit correspondence to us by post, email or via our website;
(c) order our services on our website, over the phone or by email;
(d) subscribe to our newsletter and mailing lists;
(e) fill in a form, respond to surveys, participate in promotions or use any other features of the website;
(f) register to and/or attend our events; and
(g) swap your business card;
(h) submit a CV;
(i) submit an application to a job vacancy; and
(j) attend an interview or assessment.
3.1.2 The information you provide to us may include (depending on the circumstances):
(a) Identity and contact data: title, names, addresses, email addresses, phone numbers, job title, company name, nationality, age group;
(b) Event registration data: if you’re registering for an account you may also provide a username, password and language preferences;
(c) Speaker profile data: if you’re a speaker at one of our events you may also provide language preferences, information about your academic and work history, qualifications, skills, projects, work and research that you are involved in, references, place of birth, religion, your national security number, your passport or other identity document details, headshot;
(d) Financial Data: if you are using the website to purchase products or services, you will also provide payment details, which may include billing addresses, credit/debit card details and bank account details;
(e) Employment and background data: if you are submitting a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us;
(f) Survey data: from time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey; and
(g) Sensitive information: if you are registering for an event, you may provide information about your health, dietary requirements and whether or not you have any disability (please see paragraph 3.3 below for further information about how we may use sensitive information about you).
3.2 Information we may collect about you:
(a) Information contained in correspondence: we may collect any information contained in any correspondence between us. For example, if you contact us using form on our website or by email or telephone, we may keep a record of that correspondence;
(b) Information collected at our events: we may collect any information provided, for example from business cards that you swap with AKJ. We may film the event and take photos.
(c) Transactional data: we may collect information related to your transactions with us, including the date and time, the amounts charged and other related transaction details; and
(d) Website usage and technical data: we may also collect certain information about how you use our website and the device that you use to access our website, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read paragraph 6 below.
3.3 “Special categories” of particularly sensitive personal information require higher levels of protection. Special categories of data, for example, include details about your race or ethnicity, religious beliefs and information about your health & dietary requirements.
3.4 We need to have further justification for collecting, storing and using this type of sensitive personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We process special categories of personal information in the following circumstances:
3.4.1 in limited circumstances, with your explicit written consent;
3.4.2 where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; or
3.4.3 where you have already made the information public.
3.5 If you are registering to attend an event, we will request your explicit consent to process special categories of information about your health, dietary requirements and whether or not you have any disability for the purpose of catering for your particular needs and arranging access to the event.
3.6 If you are an applicant for a vacancy, we may collect special categories of information about:
3.6.1 your race, ethnicity, religious or philosophical beliefs and sexual orientation for the purpose of our diversity and equal opportunities records (on the basis that it is needed in the public interest, for equal opportunities monitoring); and
3.6.2 your health as necessary for the purpose of arranging your interview if you are an applicant (on the basis of your explicit consent).
3.7 Information we receive from third parties
3.7.1 In certain circumstances, we may receive information about you from third parties. For example:
(a) Fraud detection agencies: Where permitted or required by law, we may receive information about you, including demographic data or fraud detection information from third party service providers and/or partners who may be based inside or outside the EU;
(b) Service providers: we may collect personal information from our website developer, IT support providers and payment services providers, who may be based inside or outside the EU;
(c) Website security: we may collect information from our website security service partners who may be based inside or outside the EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful;
(d) Social media plugins: we currently use social media plugins from the following service providers who are based both inside and outside the EU: Twitter, LinkedIn, Youtube. By providing your social media account details you are authorising that third-party provider to share with us certain information about you; and
(e) Publicly available sources: we currently use publicly available sources including publicly available content on social media, for instance to carry out identity and compliance checks.
3.7.2 We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
4.1 We will use your information for the purposes listed below either on the basis of:
4.1.1 performance of your contract with us and the provision of our services to you;
4.1.2 your consent (where we request it);
4.1.3 where we need to comply with a legal or regulatory obligation; or
4.1.4 our legitimate interests or those of a third party (see paragraph 4.3 below).
4.2 We may use your information for the following purposes:
4.2.1 To provide access to our events: to provide you with access to our events in an efficient manner (on the basis of performing our contract with you or on the basis of our legitimate interests to ensure the smooth running of our events);
4.2.2 To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
4.2.3 To process and facilitate transactions with us: we will use your information to process transactions and payments, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
4.2.5 Connections: to connect you with the sponsor of an event you have attended (on the basis of our legitimate interest in providing an exclusive networking event for stakeholders and service suppliers in the industry)
4.2.6 User and customer support: to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with enquiries or complaints about the website and share your information with our website developer, IT support provider and payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users and to comply with our legal obligations);
4.2.7 Prize draws, competitions and surveys: to enable you to take part in prize draws, competitions and surveys (on the basis of performing our contract with you and our legitimate interest in studying how our website and services are used, to develop them and grow our business);
4.2.8 Marketing: to keep in contact with you about our news, events, new website features products or services that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
4.2.9 Advertising and promotion: to deliver relevant website and social media content and advertisements and to promote and sell future events (on the basis of our legitimate interests in studying how our website/services are used, to develop them, to grow our business and to inform our marketing strategy);
4.2.10 Analytics: to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);
4.2.11 Suggestions and recommendations: to share your information with selected third parties such as our sponsors, suppliers and partners, to enable them to contact you with information about things that may interest you;
4.2.12 Research: to carry out aggregated and anonymised research about general engagement with our website (on the basis of our legitimate interest in providing the right kinds of products and services to our website users);
4.2.13 Fraud and unlawful activity detection: to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
4.2.14 Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
4.3 Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
4.3.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
4.3.2 detecting and preventing fraud and operating a safe and lawful business; and
4.3.3 improving security and optimisation of our network, sites and services.
4.4 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 10 below.
5. WHO WE MIGHT SHARE YOUR INFORMATION WITH
5.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we may share your personal information when relevant with third parties such as:
5.1.1 Our service providers: Service providers we work with to deliver our business, who are acting as processors and provide us with:
(a) website development and hosting services based in the United Kingdom;
(b) IT, system administration and security services based in the United Kingdom, Germany and France;
(c) marketing and advertising services (including the Google Adwords service), analytics providers (including Google Analytics) based in the USA;
(d) maps services (including Google Maps API), based in the USA;
(e) social media plugin services including YouTube, Twitter, LinkedIn based in the USA;
(f) payment services based in the United Kingdom and the USA;
(g) identity verification, fraud prevention and detection services which may be based inside or outside the EU;
(h) banking services based in the United Kingdom;
(i) legal, accountancy, auditing and insurance services and other professional advisers based in the United Kingdom;
5.1.2 Sponsors, partners and collaborators: we will share attendee lists with the sponsor/s, partners and collaborators of an event, for their use including for marketing purposes, as described in event delegate terms and conditions;
5.1.3 Venues where we host our events: in some circumstances where your information is required, for example, for health and safety purposes or where special access and dietary arrangements will be made on your behalf;
5.1.4 Badge printing and badge scanner companies: we may share, as relevant at certain events, your information with badge companies. This information will be deleted after the event without delay.
5.1.5 Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers who may be based inside or outside the EU and who require reporting of processing activities in certain circumstances;
5.1.6 Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
5.1.7 Prospective sellers and buyers of our business: we may disclose your personal data to any prospective seller or buyer of such business or assets. If AKJ Associates Ltd is acquired by a third party, in whole or by part, personal data about its customers will be one of the transferred assets; and
5.1.8 Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) who may be based inside or outside the EU and where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
5.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
7.1 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
7.1.1 ensuring the physical security of our offices, warehouses or other sites;
7.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption where relevant;
7.1.3 maintaining a data protection policy for, and delivering data protection training to, our employees; and
7.1.4 limiting access to your personal information to those in our company who need to use it in the course of their work.
7.2 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights, maintaining business and financial records, or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,
7.2.1 we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently; and
7.2.2 special personal data collected about attendees to our events is deleted after the event is over.
8. HELP KEEP YOUR INFORMATION SAFE
8.1 You can also play a part in keeping your information safe by:
8.1.1 keeping your devices protected by using the latest version of your operating system and maintaining any necessary anti-virus software; and
8.1.2 being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in ‘ @akjassociates.com’, ‘@e-crimecongress.com’, ‘@pci-london.com’ or ‘@securingthelawfirm.com’.
9. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
9.1 Our company is located in the UK.
9.2 We host events internationally, including outside of the EEA, and as such your personal data may be transferred outside of the EEA where relevant.
9.3 In additions, some of our external third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
9.4 Whenever we transfer your personal data out of the EEA, we aim to ensure a similar degree of protection is afforded to it by endeavouring to implement at least one of the following transfer solutions are implemented:
9.4.1 The transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
9.4.2 The Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; and
9.4.3 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. For further details, European Commission: Model contracts for the transfer of personal data to third countries; and
9.4.4 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
10. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
10.1 You have certain rights in respect of the information that we hold about you, including:
10.1.2 the right to ask us not to process your personal data for marketing purposes;
10.1.3 the right to request access to the information that we hold about you;
10.1.4 the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
10.1.5 in certain circumstances, the right to ask us to stop processing information about you; and
10.1.6 the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/).
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications.
10.2 Some upcoming new rights…
10.3 From 25 May 2018, in accordance with new data protection laws, you will have certain additional rights in respect of the information that we hold about you, including:
10.3.1 in addition to your right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/), you will also be able to lodge a complaint with the relevant authority in your country of work or residence;
10.3.2 the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
10.3.3 the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests) (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;
10.3.4 the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances; and
10.3.5 the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
10.4 How to exercise your rights
10.4.1 You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
10.5 What we need from you to process your requests
10.5.1 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.
10.5.2 From 25 May 2018, 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. We will 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. SHARING DATA DIRECTLY WITH THIRD PARTIES
11.1 You might end up providing personal information directly to third parties as a consequence of your interactions with our website and other services offered by us. For example, your name and other personal information will be shared with other website users when you correspond with them via the website, or you may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.
11.2 Please be responsible with personal information of others when using our website and the services available on it. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when it takes place outside of the website or our services.
12. THIRD-PARTY LINKS
12.1 The 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 notice of every website you visit.
13. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
13.1 We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes as relevant.
13.2 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was updated on 6th July 2018