Privacy policy

This Privacy Policy sets out how Argyll Strategy Limited (company number 14825531), with registered office at 23 Chiltern Drive, Surbiton, Surrey, KT5 8LP, United Kingdom, its subsidiaries and affiliates (further collectively referred to as “Argyll Strategy”, “us”, “our” and “we”) collects, stores, uses and otherwise processes the Personal Data (as defined below) of our online and offline visitors and other individuals (each also referred to as “User”, “you” or “your”). We hold such information as a ‘controller’.

Argyll Strategy as ‘processor’
This Privacy Policy also explains what information we may hold as a ‘processor’ on behalf of our clients (each a “Client”). As part of our business we compile due diligence, litigation and other reports (“reports”) for our Clients relating to corporates and individuals who our Clients may interact with in the course of their business (“Services”). Such information may sometimes include Personal Data which we process on the instructions of our Clients.

A ‘controller’ is the person who determines what Personal Data is collected, for which purposes and how, whereas, a ‘data processor’ is a person processing Personal Data on behalf of, and in accordance with the instructions of, the controller. For more information about controllers and processors please visit the website of the Information Commissioner’s Office at https://ico.org.uk.

What information is collected?

We may collect information about you in our capacity as ‘controller’ if you use our website, webpage or online features (further collectively referred to as, the “Website”) or contact us by e-mail, telephone or post or visit our offices.


The information may include personal identifying information such as your name, e-mail address, phone number, or information that may identify you indirectly or is capable of singling you out such as your employer details, job title and opinions of you, cookie data and other Personal Data (further collectively referred to as “Personal Data”).
We may also compile internal reports about countries, market sectors, businesses and individuals where we anticipate that such information will be useful when we are engaged to provide our Services. Most of the information will be from the public domain and we have implemented research standards designed to identify any information which may be inaccurate. Our internal reports will generally not include contact details of individuals.

Argyll Strategy as ‘processor’

We may hold information about the subject matter of our instructions, such as corporate details, names of decision-makers, corporate ownership, directorships, bankruptcy, litigation and other information available in official public records, information from social media, newspapers and other freely available publications, and images, interviews and opinions of sources about the subject matter of our reports. To the extent such information contains Personal Data, we will process it as a ‘processor’ on behalf of our Clients. Such information will generally not include contact details of any individuals. Our reports may from time to time include information about somebody’s health, ethnicity or criminal convictions from the public domain and sources.

Purposes for which we process Personal Data
As ‘controller’ Argyll Strategy will only process your Personal Data, in accordance with applicable law, for the following purposes:


  • responding to your queries;

  • handling any job application that you may make to us;

  • engaging in business to business communications with you in your capacity as a representative of a supplier, Client or another party;

  • enabling our suppliers and service providers to carry out certain functions on our behalf, including technical aspects of our Website, telecommunications, IT services and other functions;

  • sending you personalised marketing communications with your consent or as otherwise permitted by law, subject to your right to opt-out;

  • ensuring the security of our business, preventing or detecting fraud or abuses of our Website;

  • developing and improving our products and Services, for example, by reviewing visits to our Website and its various subpages to ascertain demand for specific content;

  • to comply with the instructions of our Clients and provide the Services; and

  • to comply with applicable law, for example reply to a request from a court or regulatory body, where such request is made in accordance with the law.

Argyll Strategy as ‘processor’
Generally, information obtained for our Clients may, in combination with other information, help them make informed decisions about their interactions with corporates and individual decision makers. As the ‘controller’, each Client is responsible for informing individuals of the purposes for which their Personal Data are processed. Generally, our Clients will use Personal Data processed as part of the Services for due diligence and litigation purposes.

As ‘controller’ we rely on various legal grounds to process your Personal Data. Where required by law, we will obtain your consent. However, most of our processing is necessary:


  • to fulfil a contract that we may have in place with you;

  • for Argyll Strategy’s legitimate business interest in providing, monitoring and ensuring the efficiency and security of our Website and Services; or

  • for compliance with a legal obligation to which Argyll Strategy is subject.

We compile internal reports on the basis of our legitimate interest to provide a service that enables our Clients to fulfil their legal or compliance obligation to detect and prevent fraud, dishonesty or similar acts and to protect the public from such acts. Where we collect information about somebody’s health, ethnicity or criminal convictions, we do so on the basis that such information has been made manifestly public.

Argyll Strategy as ‘processor’
Where we act as ‘processor’, our Clients as ‘controllers’ will establish the legal basis for the processing of your Personal Data, such as your consent, a contract, a legal obligation or authorisation by law or another legal basis such as legitimate interest.

Cookies


A cookie is a piece of data sent to your browser and stored on your hard drive, mobile phone or other device, containing information about you as the User.


When you arrive on our Website a pop-up message will appear informing you about cookies. In order to provide your consent, please click ‘OK’. Following your response, this message will not appear again when you revisit.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.  However, some of the services and features offered through Website may not function properly if your cookies are disabled.


Cookies can be first party or third party cookies:


  • First party cookies – cookies that the Website you are visiting places on your device.

  • Third party cookies – cookies placed on your device through the Website but by third parties, such as, Google.

The cookies placed on our Website

We use the following cookies on our Website:

Strictly necessary cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for cannot be provided.  Once you close your browser, the cookie is deactivated. You have the right to refuse our use of cookies containing information about you on your hard drive. The table below explains the cookies we use and why. These are first party cookies.

Performance cookies
These cookies collect information in an anonymous form about how our visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it and the approximate regions that they are visiting from. These are first and third party cookies, such as those listed below.

Cookie Name and Explanation

    
Google Analytics:


    • _utma
    • 
_utmb

      • 


    • _utmc

      • 


    • _utmz

    These cookies are used to build up information for the Analytics service run by Google. They allow us to run reports on how the Website is accessed, what pages are visited, and traffic sources to send visitors to the Website.  For further reading, please see Google Privacy Policy.

    Content Management System:

    • exp_tracker
    • exp_last_activity
    • exp_last_visit

    These cookies are used to improve the user experience of the Website by building up anonymous data profiles that enable us to understand User journeys and behaviour across our Website.

Social Media cookies

These cookies allow you to connect with social media networks such as LinkedIn. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
We may combine information from these types of cookies and technologies with information about you from any other source.

Opt-out

If you wish for Argyll Strategy not to send you e-mails or postal mail about our products and Services, you can opt-out by using the unsubscribe link at the bottom of the e-mail or by writing to [email protected].
If you, or another User of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our Website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/. To opt-out of being tracked by Google Analytics across our Website visit http://tools.google.com/dlpage/gaoptout.

Where we process Personal Data on the basis of your consent, you may withdraw such consent at any time.

Disclosure of your Personal Data


There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:


  • to our subsidiaries, branches or associated offices;

  • to our Clients where we share information from our internal reports about countries, market sectors,  businesses and individuals; 

  • to our outsourced service providers or suppliers to facilitate the provision of our Services and Website;

  • to third party service providers and consultants in order to seek professional advice, protect the security and integrity of our business and for business continuity reasons;

  • to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;

  • to public authorities, courts or law enforcement where we are required by law to do so; and

  • to any other third party where you have provided your consent.

Argyll Strategy as ‘processor’
Where we act as ‘processor’ our Clients control any disclosure of information. Our Services are often used for internal purposes and Personal Data will generally not be shared except with Client group companies and external advisers.

International transfer of Personal Data


We will generally not transfer your Personal Data outside the UK where most of our facilities are based. However, there may be limited circumstances where we engage a provider outside the European Economic Area (EEA) to process your Personal Data. Where this is the case we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.  If you are located in the EEA, you may contact us for a copy of those safeguards.

Argyll Strategy as ‘processor’
Where we act as ‘processor’ our Clients will control any transfers of information. Where Personal Data are transferred outside the EEA, the ‘controller’ has an obligation to put in place appropriate transfer mechanisms to safeguard it. In addition, to source the information required by our Clients we use local subcontractors who may be located outside the EEA. Where such information includes Personal Data we put in place appropriate transfer mechanisms to safeguard it as required by law.

Retention of Personal Data


Generally, our retention of Personal Data will not exceed 6 years. However, your Personal Data will be retained for longer if this is reasonably necessary for the purposes listed above or required by applicable law. For example, our internal reports may be retained for as long as the information is relevant to our Services and as long as our overriding legitimate interest exists. Please contact us for further details of applicable retention periods.
We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Argyll Strategy as ‘processor’
Where we act as ‘processor’, generally Argyll Strategy and our subcontractors delete all Client Personal Data without delay following completion of Services. However, in limited situations, we may retain Personal Data for longer periods of time where instructed to do so by the Client.

Links to other sites


You should be aware that when you are on the Website, you could be directed to other sites that are beyond our control. We cannot guarantee that the privacy policies of these websites meet our standards. As always, we recommend reading the privacy policy of any new site you go to online.

Your rights in relation to your Personal Data


Individuals have numerous rights, including the right to access, rectify, erase or restrict Personal Data, object to the our processing of Personal Data in connection with our legitimate interests, the right not to be subject to automated individual decision-making, including profiling, or the right to have Personal Data transferred to another provider. You also have the right to complain to the Information Commissioner’s Office. For more information about your rights, please visit the website of the Information Commissioner’s Office.
If for any reason you wish to exercise your rights in relation to our processing of Personal Data in our capacity as ‘controller’, you may do so by emailing to [email protected]. We will usually acknowledge your request within 5 business days. Unless an exemption applies, we will carry out your request within the prescribed statutory period (usually one month) from providing proof of identity and complying with other requirements. Your rights are not absolute and we may continue processing your Personal Data where we have an overriding legitimate ground to do so. We will inform you where this is the case. 

Argyll Strategy as ‘processor’
Where we act as ‘processor’ we will follow our Clients’ instructions to comply with any rights requests. Any such requests received by us will be passed to the Client without delay. We will be able to respond to your access request on our Client’s behalf only where we are instructed to do so.

Children


Please note that this website is not intended for children under the age of 16.

Questions or complaints


If you have any questions, complaints, or comments about Argyll Strategy or this privacy policy, you have the right to contact the Information Commissioner’s Office. However, in the first instance you are encouraged to contact Argyll Strategy by sending an e-mail to [email protected].