This privacy notice (Privacy Notice) explains how Labrys Group Holdings Limited and its wholly owned UK registered subsidiary companies (collectively LGHL, we, our, us) collects, uses and shares the personal data of: (i) its customers, contractors, suppliers and other individuals whose personal data we may process as part of delivering our services and/or (ii) of visitors to the LGHL website (the Site) hosted at www.labrys.tech (you or your). It also explains your rights in relation to that personal data
2. Updating the Privacy Notice
We may modify this Privacy Notice at any time.Please check the Site periodically for updates. This Privacy Notice was lastupdated in March 2023.
3. Data controller and contact details
LGHL (trading as Labrys) is a private limited company incorporated in England and Wales with company number 13995716 and having its registered address at The Brentano Suite Catalyst House, 720Centennial Court, Centennial Park, Elstree, Hertfordshire, England, WD5 3SY. Labrys Group Holdings Limited (or the Labrys affiliate company with whom you interact) is the data controller of your personal data and is subject to the UK General Data Protection Regulation (the UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and any successor legislation or regulations governing data protection and privacy in the UK. If you have any questions about this Privacy Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact our Data Protection Representative at firstname.lastname@example.org
4. How we collect your personal data
We may collect your personal data in a number of ways, for example:
- from the information you provide to us when you interact with us before becoming a client; when you express your interest in our services and/or fill in forms on our Site (for example, to sign-up to receive our newsletters);
- when you instruct or correspond with us by phone; email, post or via the Site;
- when you instruct us to provide services including when using our technology platforms and communication systems;
5. The types of personal data we collect
We may collect and process the following personal data:
- names, contact details (including email addresses and telephone numbers), company and organisation details
(such as role or job title) and due diligence information;
- information about your business relationship with us;
- billing and financial information;
- other information that you provide through the Site or in correspondence with us or in any enquiries you submit to us;
- other information provided to us as part of our services.
Under the UKGDPR, certain categories of personal data are recognised as sensitive, including, for example, health information or information regarding ethnicity, race, religious beliefs and political opinions. We do not seek to collect such sensitive personal data, but if it is included in information that is shared with and processed by us then this will be on the basis that: (i) we have your explicit consent to do so; (ii) the sensitive personal data is made public by you; (iii) for reasons of substantial public interest; or (iv) you volunteer this information in communications with us.
6. How we use your personal data, our legal basis for using your personal data and who we share your personal data with
6.1 Where we have a contractual relationship with you
We will process your personal data because it is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract with us.
6.2 Legitimate interests
We process your personal data because it is necessary for our or a third party's legitimate interest. Our legitimate interest include operating our business and the Site in a focused, efficient and sustainable manner. In this respect, we may use your personal data for the following:
- to assess the information that you provide to us and to find out more about you before interacting with you in response;
- to interact with you via email, telephone or via our technology and communications platforms;
- through the Site (for example, to provide core services; research services, strategic advice and consulting services, preparing reports for our clients based on the information provided to us; and other general enquiries);
- to process and verify your instructions;
- for informing our market research and business development;
- for record keeping purposes (so that we have a record of the enquiries we receive as a result of your use of the Site);
- outsourcing selected website administration functions to third parties for the purposes of the efficient management of the Site;
- to monitor and evaluate the performance and effectiveness of the Site and our communication with you, including to retain a database of our contractors; and to administer, support, keep secure or improve the Site.
6.3 Legal obligations
We may also process your personal data:
- to meet our compliance, legal and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject; and
- to deal and assist with legal claims, requests and investigations, including those made under data protection law, or requests for formal disclosure by competent authorities.
6.4 Sharing information with others
For the purposes referred to in this Privacy Notice and relying on the bases for processing as set out above, we may disclose limited personal data to a variety of recipients where there is a legitimate reason for their receiving the information including:
- with our customers;
- with our employees, agents, contractors or suppliers; and
- to administer and maintain such records as may be required by applicable laws and regulations from time to time.
6.5 Additional reasons
We may also process your personal data where:
- it is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights, property, or those of any affiliates);and
- we have your specific or, where necessary, explicit consent to do so (for example, where we process sensitive personal data because you have provided this in communications with us).
7. International transfers of data outside of the United Kingdom
Your personal data is generally only processed by us within the UK and/or European Economic Area (EEA).An adequacy decision exists in respect of transfers between the United Kingdom and the EEA. This means that the countries in the EEA to which we transfer your data (if at all) are deemed to provide an adequate level of protection for your personal data. As a matter of course, we do not transfer your data outside the EEA.
We may, however, transfer your personal data around the world on an ad hoc basis, for example where this is necessary for our interaction with you, and you are located outside of the EEA. In such circumstances, we will consider whether any additional measures are required in order to give adequate protection for the information when it is transferred.
8. How long is your personal data kept?
We will retain your personal data for as long as:
- we are interacting with you via the Site;
- for the length of any business relationship that we have with you; and
- for as long as permitted or required for legal and regulatory purposes after the last such interaction between you and us.
We use third party tracking tools service to collect standard internet log information and details of individual User behaviour patterns on the Site, such as browser cookies, We do this to analyse the performance of the Site, such as the number of visitors and interactions that website users have with the various parts of the Site. .
Further information regarding how Google Analytics use your personal data can be found here: http://www.google.com/intl/en/policies/privacy/ and https://support.google.com/analytics/answer/6004245.
10. Your rights
Under UK GDPR, you have the following rights in relation to our processing of your personal data:
- to obtain access to, and copies of, the personal data that we hold about you;
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data in certain circumstances;
- to require us to restrict our data processing activities in certain circumstances (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format, including for transmitting that personal data to another data controller;
- to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights; and
- to complain about the processing of your personal data to the Information Commissioner’s Office (ICO)
(www.ico.org.uk), although the ICO recommends that you first try and resolve the complaint with us.
If your organisation provides you with access to the Site or to Labrys services, your use is subject to your organisation's internal policies, if any. You should therefore direct your personal data privacy enquiries, including any requests to exercise your data protection rights, to your organisation’s administrator or Data Privacy Representative. Please note that the above rights are not absolute, and we may be entitled (or required) to refuse your requests where exceptions apply. For example, if we have reason to believe that the personal data we hold is accurate or we can show your processing is necessary for a lawful purpose set out in this Privacy Notice.