What is the purpose of this document?
Ecrebo Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to everyone whose personal data we process in our capacity as “data controller”, with the exception of our (current and former) employees, workers and contractors. It does not apply to data we hold as “data processor” on behalf of our clients.
This notice is not contractual and we may update it at any time. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
Data protection officer
We have appointed Michael Poyser as our data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please e-mail him at firstname.lastname@example.org.
Data protection principles
Ecrebo must comply with the principles relating to processing of personal data set out in the GDPR which, in summary, state that personal data shall:
- be processed fairly and lawfully in a transparent manner;
- be collected for specific, explicit and legitimate purposes and not be processed in any manner which is incompatible with those purposes;
- be adequate, relevant and limited to what is necessary for that purpose;
- be accurate and kept up to date where necessary, with every reasonable step being taken to ensure that personal data are accurate, having regard to the processing purpose, and are erased or rectified without undue delay;
- be kept in a form which permits identification of data subjects for no longer than is necessary for that purpose;
- be kept secure, safe from unauthorised access, accidental loss, damage or destruction; and
- be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction of damage, using appropriate technical or organisational measures.
The kind of information we hold about you and what we do with it
We collect contact details (name, address, e-mail address, telephone number, job titles and organisation details) of clients, potential clients, suppliers, advisers, collaborators and other stakeholders. This information may be used for the legitimate interest of communicating with you in relation to specific matters that you are involved in, or matters that you might be able to assist with. We may also contact you to keep in touch or make introductions.
We use the contact details of our shareholders to send them updates about the business and their investment in it as well as agreements, resolutions and documents relevant to their shareholding. We
also provide their name and shareholding details, as well as the name, home address, service address, date of birth, occupation and nationality of directors, to Companies House.
If you apply for a job with Ecrebo, we will keep your name, contact details, current salary and CV and may use these to contact you about applicable jobs.
We may share your personal information for our legitimate interests in the context of the possible sale, transfer or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the buyer (and their group companies and professional advisers to the extent relevant) before the transaction completes. Once the transaction is completed, we will share your personal data with such recipients if and to the extent required under the terms of the transaction or required by law.
We may provide your personal details, as appropriate for our legitimate interests or to comply with our legal obligations, to our banks, accountants, auditors, insurers and professional advisers, who are not permitted to use this data for their own purposes.
We may share your personal information with our US subsidiary, Ecrebo Inc, to the extent that it forms part of our regular reporting activities on company performance, to achieve best practice across the businesses and to share know-how and market information, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
Who may see your data
Our IT support and office management system providers have access to all data on our systems to provide their services to us for legitimate interests. We use G-Suite for our e-mail exchange, which is provided by Google. We only allow our third-party service providers to use your personal data for specified purposes and in accordance with our instructions.
Special categories of personal information
"Special categories" of particularly sensitive personal information, such as information about a person's health or sexual orientation, require higher levels of protection.
We are unlikely to store any “special category” data about you unless you specifically provide this to us and consent to us doing so.
If you are disabled, we may collect, store and use information regarding your disability in order to make adjustments to our premises or find a suitable alternative for meetings with you and to ensure your health and safety at our premises.
We will not store or use information about any criminal convictions and offences, unless you have provided your consent to it.
Any personal data may be held and used for establishing, exercising or defending legal claims.
In limited circumstances, we may approach you for your written consent to allow us to process other sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information, whether sensitive or not.