LAUREL INSIGHTS PRIVACY NOTICE (EU/UK)
OUR COMMITMENT TO PRIVACY
At Laurel Insights LLC (“ Laurel Insights”) we provide interview-based qualitative research and analysis to our clients (“ Services”). Your privacy is important to Laurel Insights and our affiliates (together, ‘our’, ‘us’, ‘we’ or ‘company’). We are committed to protecting the privacy of our website visitors, clients and, as a qualitative research firm, the privacy of research respondents in connection with the provision of our Services.
This privacy notice (“ Privacy Notice”) describes how we process your personal data in connection with the provision of our Services, our website: https://laurelinsights.com/, and other data collection points where we refer to this Privacy Notice.
For the purposes of applicable data protection laws in the United Kingdom (“ UK”) and European Union (“ EU”), including Regulation (EU) 2016/679 (the “ EU GDPR”), the UK equivalent of the EU GDPR (the “ UK GDPR”) and the Data Protection Act 2018, (together, “ EU and UK Data Protection Laws”) Laurel Insights will be a controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this Privacy Notice, please contact Laurel Insights Admin at 111 Town Square Place, Suite 1201, PMB 1274, Jersey City, NJ 07310.
This Privacy Notice is intended to assist you in making informed decisions when using our website and our Services. Please take a moment to read and understand it. You do not need to take any action as a result of this Privacy Notice, but you do have certain rights as described below in the section headed “ Your rights”.
THE TYPES OF PERSONAL DATA WE PROCESS
In providing our website and Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our website and Services and includes the following:
Identity Data: first name; last name.
Contact Data: email addresses; telephone numbers.
Respondent Data: first name; last name; country; job title; whether you have participated in any interview, survey or questionnaire.
Behavioural Data: data relating to your browsing activity or interaction with our emails, pixel tags and other similar technologies; information about when your current or previous sessions started.
Technical Data: IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Publicly Available Data: information about articles (or similar) that you may have published or other publicly available social media related information.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW WE COLLECT AND RECEIVE PERSONAL DATA
We collect your personal data in the following ways, and we only collect the personal data necessary to carry out our business for the purposes set out in the section below headed “ Why we use your personal data”:
Information you provide to us.
We collect your personal data when you decide to interact with us. You may give us your personal data directly, for example, when you agree to take part in our research, or when you provide your Contact Data as part of an interview or survey, contact us with enquiries, complete forms on our website, or provide feedback to us.
Information provided by third parties or publicly available sources.
We may receive personal data about you from third parties. Such third parties may include our clients, market research sample and list suppliers, analytics providers, data brokers and third party directories.
From time to time, we may collect personal data about you (Identity Data and Contact Data) that is contained in publicly available sources (including open-source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through publishing articles or other news stories or posts on social media platforms).
WHY WE USE YOUR PERSONAL DATA
We may use your personal data for the following purposes:
Purpose
Legal Basis
Fulfilment of our Services and to conduct our business (for example, carrying out interview-based qualitative research and analysis, surveys and/or questionnaires)
Contractual necessity; and/or our legitimate interest in operating our business.
To communicate with you, to schedule and facilitate online interviews and to administer your participation in any of our events
Our legitimate interest in operating our business.
To keep a record of your relationship with us
Our legitimate interest in operating our business; and/or legal requirement
Litigation management and conducting internal audits and investigations
(as needed to respond to regulatory or other compulsory document requests)
Legal requirement; and/or our legitimate interest in operating our business
To obtain advice from our professional advisors, including lawyers and accountants
Our legitimate interest in operating our business
To administer and protect our business and this website
Our legitimate interest in operating our business
To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you (to communicate with you or to provide other updates and communications regarding our business activities)
Our legitimate interest in operating our business
For any other purpose that has been notified, or has been agreed, in writing
Consent
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.
No solely automated decision making, including profiling, is used when processing your personal data.
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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.
HOW WE OBTAIN YOUR CONSENT
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “ Contact Us” section below.
DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. When processing your personal data, we may need to share it with third parties, as set out below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
Our clients, who we may share personal data with for the purposes of providing them with our Services, and who may use your personal data to evaluate prospective investments.
Our service providers that provide a wide range of services including legal and financial professional advisors, our auditors, consultants, IT and data security providers, and data hosting providers; and
Other third parties. We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.
We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.
To the extent your personal data is transferred to countries outside of the UK, EU or the European Economic Area (“ EEA”), such transfers will only be made in accordance with applicable laws. Furthermore, we may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfil the purposes described in the Privacy Notice and in accordance with applicable laws. For further information about the safeguards used, please contact privacy@laurelinsights.com.
For the purposes of this Privacy Notice, “ Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA or EU; (ii) the United Kingdom; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EU and UK Data Protection Laws to ensure an adequate level of protection for personal data.
SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies, measures and policies, so the information we have about you is protected to the extent possible from unauthorized access and disclosure, improper use and accidental loss. 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 and required to keep your personal data secure.
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.
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law.
We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact privacy@laurelinsights.com.
CAPACITY
This website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 13 or knowingly collect personal data from anyone under the age of 13 without parental consent. If we learn we have collected or received personal data from an individual under the age of 13, we will delete that information.
YOUR RIGHTS
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact privacy@laurelinsights.com.
Access: You have the right to ask for a copy of the personal data that we hold and process about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal data if the information we hold and process about you is inaccurate or it needs to be updated.
Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Automated decision-making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this Privacy Policy, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
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.
NOTIFICATION OF CHANGES
We reserve the right to amend this Privacy Notice from time to time by updating this Privacy Notice. If we decide to change our Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Privacy Notice under which the personal information was collected.
CONTACT US
If you have any questions or concerns about this Privacy Notice, please contact privacy@laurelinsights.com.
COMPLAINTS
Should you wish to lodge a complaint with regards to how your personal data has been processed by us under:
the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.