LAST UPDATED: 23 September 2020
Newpearl Strategy is committed to protecting your personal data. We want you to be familiar with how we collect, process, use and disclose your personal data. This notice (the “Privacy Policy”) describes our practices in connection with any personal data we collect from you, or that you provide to us.
By visiting newpearlstrategy.com or making use of any of the services listed in the “Our Services” section below, you are accepting and consenting to this Privacy Policy.
1. Important information
Controller
Newpearl Strategy Limited is a private limited company incorporated in England and Wales with registered number 11809006. As the controller of your personal data, Newpearl Strategy is therefore responsible for any collection, processing, use and disclosure that may be carried out in relation to your personal data.
References to the terms “we”, “us” and “our” in this Privacy Policy are to Newpearl Strategy.
Purpose of this Privacy Policy
It is important that you read this Privacy Policy together with any other privacy policy update or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you.
Updates to this Privacy Policy
This Privacy Policy may be updated from time to time. The “Last Updated” section at the top of this page indicates when this Privacy Policy was last revised. Any changes that we make to this Privacy Policy will be effective from the date specified at the top of the revised Privacy Policy. Your use of our services following any such changes indicates that you have accepted them.
Duty to inform us of changes
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
Our 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. Our services
Newpearl Strategy is a business that offers crisis communications and public affairs support. In order to provide our services, we may collect personal data through a number of sources. Please see the ‘How is your personal data collected’ section for more information.
Where we need to collect personal data by law, or under the terms of a contract we have (or are negotiating) with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of the services you have with us, but we will notify you if this is the case at the time.
3. How we process and use your data
“Personal data” is information that identifies you as an individual or relates to an identifiable individual.
We will only use your personal data when the law allows us to and we will not sell, trade or otherwise deal with your personal data in any way that contravenes this Privacy Policy (as may be updated from time to time).
We have set out below a description of the ways we plan to use your personal data, and on which legal basis we do so. Where we rely on our legitimate interests as a legal basis for processing, we have identified the nature of those legitimate interests.
Basis for use and processing
(1) Providing our services and managing our relationship with you:
to provide services or proposals to you;
provide general advice and support;
maintaining a record of contacts;
organising meetings with you;
to respond to your enquiries and fulfill your requests, when you contact us for example, when you send us questions, suggestions, or feedback, or other information about, our services; and
to complete your transactions, and provide you with related client or investor related services.
Name
Residential address
Date of birth
Tax ID / national insurance number
Passport or similar documented identification
Nationality
Email address
Telephone / mobile number(s)
Bank account details
Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)
(2) Marketing communications and newsletters
Name
Residential / office address
Email address
Nationality
Job title / position of responsibility
Name of employer
Necessary for our legitimate interests (to develop our services, to grow our business and to inform our marketing strategy)
(3) Dealing, managing and considering job / employment applications
Name
Residential address
Date of birth
Tax ID / national insurance number
Passport or similar documented identification
Nationality
Email address
Telephone / mobile number(s)
Job title / positon of responsibility
Curriculum vitaes (CVs)
Employment history
Necessary for our legitimate interests (for providing our services, running our business, and administrative purposes)
To allow the performance of contractual relations with you
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such 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. 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.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise.
4. 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 personal 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 for our products or services;
complete an online submission form;
request marketing to be sent to you;
employment applications;
submitting funding applications and any related materials including slide decks, presentations and web submissions;
give us some feedback;
use our website (www.newpearlstrategy.com); or
use our social media pages including Twitter, LinkedIn, Facebook and Medium.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this personal data by using server logs and other similar technologies such as IP address identification and logging.
Cookies. Newpearl Strategy may also use cookies to collect information on you such as your browser type, time spent on the services, pages visited, language preferences, and other traffic data. For more information on our use of cookies, please see our Cookies Policy. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. If, however, you do not accept cookies, you may experience some inconvenience in your use of the services.
Third parties or publicly available sources. We may receive personal data about you from various third parties including analytics providers, advertising networks and search information providers.
Identity data from data brokers or aggregators.
Public sources. Identity data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
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.
5. Disclosures of your personal data
Newpearl Strategy will only disclose personal data in accordance with this Privacy Policy (as may be updated from time to time), General Data Protection Regulation and UK laws such as the Data Protection Act.
We may disclose personal data to third party service providers (including IT system administrators, professional advisers, providers of finance, HM Revenue & Customs, regulators and other authorities) to facilitate services they provide to us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In such circumstances, 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.
International transfers
Newpearl Strategy is based in the European Economic Area (“EEA”). If we transfer personal data to our group or affiliate entities or to third parties outside of the EEA, we will ensure your personal data is protected, for example by ensuring one or more of the following safeguards is implemented:
We will only 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.
Standard contractual clauses approved by the European Commission are in place with the transferee.
Where we transfer personal data to service providers or affiliates 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. 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 cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the internet and will not hold Newpearl Strategy responsible for any breach of security unless this is due to Newpearl Strategy's negligence or willful default.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
You can request details of retention periods for specific categories of your personal data by contacting us.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:
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; and
right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
We give you choices regarding our use and disclosure of your personal data for marketing purposes. You may opt-out from receiving electronic communications from us by contacting us or by following the ‘Unsubscribe’ link provided at the footer of any marketing materials that you may have received from Newpearl Strategy by email.
Complaints
You have the right to lodge 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 we would encourage you to contact us in the first instance.
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. 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.
9. Contact Details
If you have any questions about this Privacy Policy, please contact our data privacy representative using the details set out below.
We may be contacted at:
Alisa Helbitz
Newpearl Strategy Limited
Email: alisa@newpearlstrategy.com
PLEASE NOTE: Newpearl Strategy also uses info@newpearlstrategy.com or general queries. For queries related to our Privacy Policy or use of your data, please clearly specify “Privacy Policy” in the subject so that we can more easily respond.