(Last Updated: June 2019)
Gravitas is a trading name used by Gravitas Worldwide Ltd and this is communicated with our suppliers and clients.
Gravitas takes privacy seriously. The following principles underpin Gravitas’s approach to respecting your privacy:
We value the trust that you place in us by giving us your personal information. We will always use your personal information in a way that is fair and worthy of that trust.
We will provide clear information about how we use your personal information. We shall always be transparent with you about what information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns.
We will take all reasonable steps to protect your information from misuse and keep it secure.
We will comply with all applicable data protection laws and regulations and we will co-operate with data protection authorities. In the absence of data protection legislation, we will act in accordance with generally accepted principles governing data protection. For the purpose of the Data Protection Act 1998 (the “DP Act”), the data controller is Gravitas.
1. INFORMATION THAT WE MAY COLLECT FROM YOU
Gravitas is what’s known as the ‘controller’ of the personal data you provide to us. We will usually collect basic personal data about you like your name, postal address, telephone number, email address if you are either a client or supplier to the group we collect the data given on the application. We may collect information about certain supporters (e.g. particularly well known or influential people) from public sources. This could include public databases (such as Companies House), news or other media.
We may conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you. Our section on Research and profiling contains more information about how we may use information for pro ling and targeted marketing.
We do not normally collect or store sensitive data (such as information relating to health, beliefs or political affiliation) about clients and suppliers.
If this does occur we will be very clear with you that we wished to collect such information, our reason for collecting such information, and we would only do so with your specific consent and permission. We’ll also take extra care to ensure your privacy rights are protected.
2. WE MAY COLLECTION THE FOLLOWING INFORMATION:
• Information provided by you in the completion of the forms on or as indicated by you on the accounts settings page of our Site. This would include information provided at the time of registering to use our Site, subscribing to or requesting services, updating of your account settings and reporting problems with our Site. The information you give us may include your name, address, email address, phone number, financial information, date of birth, location and third party application profiles.
• We may keep a record of all correspondence should you contact us, including any information provided if you report a problem with our Site.
• Details of transactions you carry out through our Site and of the fulfilment of any services requested.
• Details of your visits to our Site including, but not limited to, traffic date, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources you access.
• We may make other tools available to sync information with our services, and may also develop additional features that allow users to use their account in conjunction with other third-party services.
We may collect information about your computer, including where available your IP address, operating system, login information, browser type, time zone setting, browser plug in types and version for system administration, the full URL clickstream to, through and from the Site, products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
3. WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
• Internal record keeping.
• To carry out any obligations owed to you through the use of our Site and in respect of any contracts entered into between you and us.
• To notify you about changes to our service.
• To notify you about changes to our rates and charges.
• To notify you about updates with current jobs you have booked through us.
• To ensure that the content from our Site is presented in the most effective
manner for you and your computer.
• To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• As part of our efforts to keep our Site safe and secure.
• To improve our services.
We may periodically send promotional emails about new features, products, or other information you have requested from us or that we feel you may nd useful and interesting unless you indicate that you do not wish to be contacted for such purposes.
• We use personal data to communicate with people, to promote Gravitas. This includes keeping you up to date with our news, updates, campaigns and our rates. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about Gravitas and its work worldwide)
• You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us by emailing email@example.com, writing Gravitas , 13 Bentalls Business Park, Basildon, Essex, SS14 3BN or telephoning 01268 286999 (Lines open 9am – 5pm, Mon – Fri).
• When you receive a communication, we may collect information about how you respond to or interact with that communication, and this may affect your communication preferences.
3b. Sharing your information
We only disclose information to third parties or individuals when obliged to by law, for purposes of national security, taxation and criminal investigations and the following:
• If you have agreed that we may do so.
• When we use other companies to provide services on our behalf, e.g. processing, mailing or delivering orders, sending mail and emails, customer analysis or when using auditors/advisors or processing credit/debit card payments.
• If we receive a complaint about any content you have posted or transmitted to or from one of our sites, to enforce or apply our Terms & Conditions or if we believe that we need to do so to protect and defend the rights, property or personal safety of the Gravitas, our websites or our visitors and for other lawful purposes.
• If we merge with another organisation to form a new entity, information may be transferred to the new entity.
And, we will never sell or rent your personal information to other organisations.
4. STORAGE OF INFORMATION AND SECURITY
We are committed to maintaining the highest standards of data security.
All information you provide to use is stored on our secure servers. Any payment transactions will be encrypted using commercial grade encryption technology. We are committed to ensuring that your information is secure and have put in place various physical, electronic and managerial procedures in order to attempt to safeguard and secure the information we collect online. Unfortunately, however, the transmission of information via the internet is not completely secure and whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site. Accordingly, any transmission is at your own risk.
Where we have given you or you have chosen a password that enables access to all or part of our Site, you are responsible for keeping this password confidential and we would ask that you do not share this password.
6. LINKS TO THIRD PARTY WEBSITES
7. DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site. We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Gravitas or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of Gravitas, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
• With your consent.
8. CONTROLLING YOUR PERSONAL INFORMATION
You have the right to restrict the collection or use of your personal information. If you do not wish to be contacted by Gravitas in our periodic newsletters, simply click the “unsubscribe” link in the footer of any of these emails that you receive.
You have the right to request details of personal information which we hold about you under the DP Act. In most cases, there will be no charge, in providing you with details of the information we hold about you, however we reserve the right to charge a reasonable fee when a request is manifestly unfounded, excessive or repetitive. If you would like a copy of the information held on you please write to Gravitas at GDPR@Gravitasworldwide.com.
All processing of personal data by Gravitas is in accordance with the eight data protection principles set out in Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data, as implemented in the United Kingdom by the DP Act.
We make reasonable commercial efforts to ensure content on the Site is up to date and accurate, however, because we get the content from a number of different sources (including information provided by you) we do not endorse, support, represent, warrant or guarantee the completeness, truthfulness, accuracy, or reliability of any such content. If you do become aware of any inaccurate or incorrect content accessed or accessible using our Site (in particular pertaining to yourself or other individuals) please let us know at GDPR@Gravitasworldwide.com and we will use our reasonable endeavours to investigate your concern and, where appropriate and possible, correct inaccurate data.
Content relating to credit scores, in particular, is provided and generated by a third party source, should you have any concerns as regards inaccurate or incorrect content in this regard please also contact us at GDPR@Gravitasworldwide.com and we will use our reasonable endeavours to pass your concern onto the appropriate third party provider. You understand that by using our Site, you may be exposed to content that might be inaccurate or deceptive. Under no circumstances (save as required by law) will we be liable in any way for any content accessed, or any loss or damage of any kind incurred as a result of the accessing by you of our Site.
We hold your information only as long as necessary for each purpose we use it and regularly review what information we hold and delete what is no longer required.
10. DATA SECURITY
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
Our electronic data is stored within secure servers in the United Kingdom. Personal Data that is kept on paper copies is stored in secure locked cabinets.
11. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. A new data protection law, which started in May 2018, gave everyone a number of very important rights. These are:
• the right to ask us to remove your personal data from our records (though this will not apply where it is necessary for us to continue to use the data for a lawful reason)
• the right to have inaccurate data rectified
• the right to request a copy of the information we hold about you
• the right to ask us to stop using your information for marketing or profiling, and
• where technically feasible, the right to obtain and reuse your personal data for your own purposes. Remember, you can change the way you hear from us or withdraw your permission for us to processing your personal data at any time by using the contact details in the How to Contact Us section
Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and Gravitas. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.
Gravitas complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices so you know when CCTV is in use.
13. LEGITIMATE INTEREST
Under the new data protection law starting in May 2018 we have a number of lawful reasons that we can use (or ‘process’) your personal information. One of these lawful reasons is called ‘legitimate interests’.
Broadly speaking Legitimate Interests means that we can process your personal information if:
We have a genuine and legitimate reason and we are not harming any of your rights and interests.
So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests to carry out our work. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.
Gravitas will use various ways to achieve our mission and to support our objectives: we believe that people who share our values would love to know how to support us. We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’ for holding and processing your data.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by contacting us. For our details please see section 11.
Gravitas may change this policy from time to time by updating this page. If you have an existing relationship with Gravitas, you will be notified of these changes.