PRIVACY STATEMENT

1 INTRODUCTION

gb2 (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

This Privacy Statement is aimed at our client contacts, suppliers, job applicants, individuals who may be the subjects of a project and visitors to the gb2 website (www.gbsqd.com) (our “Website”).

2 SECURITY

We take the security of all the personal data we hold seriously. However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or by email; any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3 DATA THAT WE

HOLD

3.1 Professional Services

We only provide services to businesses. The personal data we process further to the provision of our services will depend on the services to be provided and what our clients choose to send us. The lawful basis for processing that data is to comply with our contracts with our clients or in anticipation of such contractual obligations. Our clients are the data controllers and we are data processors as defined by European and UK data protection legislation.

We request that clients only provide the personal data that is required for us to fulfil our contractual obligations.

3.1.1 Why do we process client personal data and what is our lawful basis for doing so?

Where personal data is collected it is used for several purposes, as follows;

Providing services to clients. Personal data is processed in accordance with our letter of engagement and/or the Data Protection Agreement between our clients and us and may sometimes be further clarified in written documentation supplied before any data processing occurs. We provide a range of professional services to our clients, which includes:

Client management. When communicating with and assessing the needs of clients we will need to use personal information in order to contact and update the client, and to ensure that client needs are appropriately satisfied and to comply with our contractual obligations to clients or in anticipation of such contracts.

Our services often require us to process personal data relating to third parties which is provided to us by our clients. We do this in accordance with the terms of our client contracts.

Administration. To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes. The lawful basis for this processing is our legitimate interest.

Regulatory. To undertake professional services, we may from time to time be required to collect and process personal data to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.

3.1.2 What personal data is processed?

The personal data that is processed is dependent on the service that is being provided and what our clients send us and what we need to process to comply with regulatory requirements.

Typically personal data may include any relevant financial or non-financial information necessary for us to provide our services such as contact details, payroll data, employee information (including details about dismissal), lists of names and/or addresses and/or other relevant contact information for shareholders, customers and suppliers and any other specifically relevant personal data.

In addition, we process contact details for our clients, personal details provided to us by job applicants, and information on visitors to the Website.

3.1.3 How long do we hold data for?

“Services” Personal Data

We retain the personal data processed by us further to the supply of our services in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (and thereafter as required by applicable law or regulation, typically 6 years and 3 months from the date on which the provision of the Services is concluded or terminated). We may keep personal data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.

When a contract is completed personal data is securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it beyond the completion of a contract.

3.2 Business Contact information

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees are held in our individual email databases and on our server which are all password protected. The lawful basis for our processing of such data is that it is in our legitimate business interest to do so.

3.2.1 Why do we process business contact data and what is our lawful basis for doing so?

Where personal data on business contacts is held, it is used for several purposes, as follows;

Promote and develop our offerings.
Communication of technical updates.
Hosting and facilitating of events.
Relationship management.
Administration and management.

The lawful basis for our processing of such data is therefore either contractual or we have a legitimate business interest.

3.2.2 What data do we hold?

Personal data that may be stored includes, but is not limited to, name, email address, physical address, job title, and details of meetings.

3.2.3 How long do we hold data for?

We retain the personal data processed by us for as long as it is considered necessary for the purpose(s) for which it was collected provided that we have a legitimate interest to do so.

3.3 Suppliers

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them.

3.3.1 Why do we process supplier personal data and what is our lawful basis for doing so?

The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive their goods and services and our lawful basis is contractual.

Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients. Again, our lawful basis is contractual.

Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:

- managing our relationship with suppliers;

- developing our businesses and services (such as identifying client needs and improvements in service

delivery);

- maintaining and using IT systems;

- hosting or facilitating the hosting of events; and

- administering and managing our website and systems and applications.

The lawful basis for this type of processing is legitimate interest.

Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data. The lawful basis for this type of processing is our legitimate interest.

Promoting our services. We may use business contact details to provide information that we think will be of interest to you about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events. The lawful basis is legitimate interest. If you receive such updates or invitations and do not wish to do so you should tell us and we will remove you from our mailing lists.

Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data so the lawful basis for this type of processing is to comply with our legal obligations.

3.3.2 What data do we hold?

We will hold supplier’s contact names and contact details.

3.3.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and to establish, exercise or defend our legal rights.

3.4 PEOPLE WHO USE OUR WEBSITE

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry, comment on publications, enter a competition, promotion or survey, apply to work for a gb2 business and report a problem with our websites.

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

3.4.1 What personal data do we hold and on what lawful basis?

The personal data that we hold depends on what personal data was entered by the visitor to our website, caller or emailer, and for what purpose.

Where personal data is entered to engage with the functionality of our website, that personal data may include your name, address, e-mail address and phone number.

Cookies: The only Cookies on our site that are enabled are those used solely to carry out or facilitate the transmission of communications over a network; or strictly necessary to provide an online service (e.g. our website or a service on our website) which you have requested. Where this means that personal data is collected automatically as a result of a visit to our website, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Such personal data is processed further to our legitimate interest and/or your consent. If you do not wish to us to process your personal data in this way please do not access our site.

3.4.2 How long do we hold personal data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation) typically 6 years from the last date on which a user accessed our website.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

4 SHARING

PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

- Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.

- Third party organisations that otherwise assist us in providing goods, services or information

- Group companies including gb2 LLP and gb2 Limited

- Auditors and other professional advisers

- Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

5 LOCATIONS OF

PROCESSING

Where possible, personal data remains within the UK but may be transferred to, and stored at, a destination outside the European Economic Area (EEA) where we have legal appropriate safeguards in place. (In the event of Brexit and no adequacy decision (or similar) being granted by the EU Commission for the UK then such safeguards will also be in place with third party recipients within the EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement and in accordance with applicable data protection laws.

We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU (or if applicable, the UK) are done lawfully. Where we transfer personal data outside of the EU (or if applicable the UK) to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

6 INDIVIDUAL'S

RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

Individuals may request access to their personal data held by us as a data controller.

Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.

Individuals may request that we erase their personal data.

Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.

Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.

Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to info@gbsqd.com.

7 COMPLAINTS

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to info@gbsq.com. We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner's Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

8 CHANGES TO

OUR PRIVACY

STATEMENT

Updates to this privacy statement will appear on this website. This privacy statement was last updated on 1 September 2020.