Privacy Policy – Aims Consultancy

AIMS Consultancy Website Privacy Notice

Context and scope

This privacy notice is to give you information on how we collect and process personal data through use of our services. It is important that you understand this privacy notice, and if you are also a client of ours, that you read it together with our agreements and support policy.

We may update this notice from time to time. Where a change is significant, such as this latest update because of GDPR, we’ll make sure we let you know, usually by sending you an email if you are an AIMS Consultancy client.

Who we are and how to contact us?

AIMS Consultancy Limited (company registration number 07590314) is the organisation behind AIMS Consultancy. This privacy notice is to give you information about how we collect and process personal data in accordance with our obligations.

You can contact us at any time or engage our Data Privacy Officer by directly.

Our postal address is:

AIMS Consultancy,
Chequers House,
Watton Rd,
Ware,
SG12 0AA

Telephone: 0845 431 0295

E-mail: admin@aimsconsultancy.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO. So please contact us through one of the ways above, or perhaps speak to your account manager in the first instance.

As a responsible supplier we really want to help where we can do so. Our philosophy for data protection and privacy extends beyond personal data into the protection and privacy for all valuable information.

Personal Data

Personal data means different things to different people, so we adopt the meaning from the General Data Protection Regulations (GDPR) and The Data Protection Act (2018). Personal data we process includes data such as;

First name,
Surname,
Email address,
Profile photo,
IP address,
Job role,
Contact information.

Where we do deal with financial details; Payment and banking information is generally provided at a corporate information level but it will also be considered personal data where, in the unlikely event, an individual is paying for the services from their own account and we may need to know some of that banking or credit card information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to determine the attractiveness of a feature or evaluate performance for future investments. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may be relieved of that specific contractual obligation or choose not to proceed with a request, but we will notify you if this is the case at the time.

Collecting personal data

When you visit our website or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:

Provided directly by you – for example by completing our website forms, signing up for our newsletter, calling in for help, applying for a job, or by contacting us for support. You don’t have to share much personal data at all to benefit from the services and can always ask us to remove that later too. If you choose not to share the relevant personal data, you understand that might mean we cannot provide the services.

Collected automatically – we collect information such as IP address, device type, pages you visited and what links you clicked on. For our website and marketing work this means we can get a better understanding of user journeys and areas of interest, so we can keep providing great experiences and personalising content where appropriate. Some of this information is collected using cookies and related tracking technologies, including google ads.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our services may become inaccessible or not function properly. Our cookie policy explains that in more detail.

Information we get from other parties – We might seek to find out more about someone from publicly available sources, or through reputable, qualified sources such as marketing and research organisations. We use this information to better personalise our services and on occasion to validate personal data you may provide.

AIMS Consultancy services are not intended to be marketed to, sold to or used by children. In our capacity as a data controller we do not knowingly collect data relating to children. If you think children’s information is being processed by us in our role as a data controller please contact us.

How we share your personal data

We will not share your personal data with any other company for marketing purposes.
Your data may technically be shared for the purpose of sub processing as part of a contract we have with a third party supplier, for example a third-party data centre processing information on our behalf.

We may also be required to share your data with law enforcement, government agencies, courts or regulators in order to comply with applicable laws. Where allowed, we will notify you of this type of disclosure. Your data may also be shared with a potential acquirer or investor of our company, or any part of it, and any other people where we have your consent.

Lawful basis for use of your personal data

We will only use your personal data when the law allows us to, following one of the lawful bases within the GDPR. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract,we are about to enter or have entered with you.
• Where it is necessary for our legitimate interestsand, your interests and fundamental rights do not override those interests. In those instances, we will have conducted a Legitimate Interest Assessment.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given your consent.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

You have the right to withdraw consent or opt out at any time by contacting us or using the relevant mechanism provided in the communication at the time e.g. unsubscribe from a mail marketing campaign, or ‘do not contact’ response in a specific email sent by one of our staff.
Once opted out a minimal amount of data will be held in a suppression / do not contact list so that we avoid any future contact.

Purposes for use of your personal data

We have set out below, in a simple table format, a description of the ways we might use your personal data, and which of the legal bases we rely on to do so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity	Type of data	Lawful basis
To deliver our services and related support for you as a client.	First name Surname Email address	Performance of a Contract
To process and deliver your order including managing payments, collecting and recovering debts.	First name Surname Phone number Address (business) Payment information	Performance of a Contract (and Legitimate Interests if pursuing a debt)
To market and promote our services to prospective clients	First name Surname Job role Email address Contact number	Consent Legitimate interests
To use data analytics to report on and improve our website, products/services, marketing, customer relationships and experiences	First name Surname Email address IP address	Legitimate interests Performance of a Contract (if not using aggregated reporting and anonymised information)
To prevent incidents, protect customers and respond quickly to security issues	First name Surname Email address Phone number	Performance of a Contract Necessary to comply with a Legal Obligation
To respond to legal or regulatory demands	Any or all information held depending on the request	Necessary to comply with a Legal Obligation

Set out below is a little more about the types of lawful basis that we will rely on to process your personal data.

Legitimate Interest – means the interest of our business in conducting and managing our business to enable us to give you the best service/product and a secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do this using a Legitimate Interest Assessment and you can learn more about that by going to the ICO website. We do 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). You can also contact us for further information about how we assess our legitimate interests against any potential impact on you.

Performance of Contract – means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation – means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International transfers

Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data including by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).

Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the EEA.

Data protection and security

We have put in place measures to protect the confidentiality, integrity and availability of your personal data. This includes following the principles of ISO 27001:2013 and a host of other security practices. We aim to be a responsible supplier and prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, and avoid it being altered or disclosed where it shouldn’t be. 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 reason. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality and each one has relevant contracts in place to reinforce that aim.

We have also 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. Our intent is to notify within 24 hours or as soon as we become aware of any breach.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Following that period, we’ll make sure it’s deleted or anonymised.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, by law we have to keep basic information about clients for 6 years for tax and other purposes after they cease being customers. Depending on the use of AIMS Consultancy some personal data may still be held because it is part of an initiative you contributed to that is still in existence and your organisation wants an audit trail.

In some circumstances you can ask us to delete your data and request erasure as one of your legal rights, as set out below.

Your legal rights

You have legal rights for your personal data and in summary these are:

Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

We have policies and practices in place for each of these requests so if you wish to exercise any of them please contact us and we will process that accordingly. 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. We try to respond to all valid requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You will not normally have to pay a fee for exercising your legal rights if the request is straightforward and valid. In the event the request is repetitive, excessive or unreasonable we will charge a reasonable fee. We may also choose to refuse a request. In this instance ICO guidance will be followed when choosing not to respond and this will include an explanation why, informing you of your right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.

Explanation about your Legal Rights

You have the right to:

Request accessto your personal data (commonly known as a “Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected or deleted, though we may need to verify the accuracy of the new data you provide to us.

Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processingof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transferof your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can contact us at any time through support @aimsconsultancy.co.uk or engage our Data Privacy Officer.

Cookie Notice

A cookie is a small text file that is placed on your computer or device when you visit our website or use AIMS Consultancy itself. We, and some of our third-party service providers, like Google, may use a few different types of cookies. Some are persistent cookies (cookies that remain on your hard drive for an extended period) and some are session cookies (cookies that expire when you close your browser).

We also use other tracking technologies like web beacons (sometimes called “tracking beacons” or “clear gifs”) and local storage. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our websites or opened an email that we have sent them.

Cookies helps our website load faster when you come back, it also gives us information about who is visiting our website so that we can improve it. Cookies do not give us personal information.

If you wish you can prevent the use of cookies and you can do this by activating the facility which is available in most web browsers and enables the user to deny or accept cookies. However, you should know that certain essential cookies may be necessary in order to provide you with certain features of AIMS Consultancy so if you deactivate them your service will not work as intended.

The types of cookies we use are always changing. Check back regularly to make sure you stay up to date. We are not responsible for the privacy policies and practices of any third-party links or services not in our control.

Third party cookies

Google Analytics
Visit https://www.google.com/analytics/ to find out more about Google Analytics and https://policies.google.com/technologies/cookies for information about how Google uses cookies.

LAST PUBLISHED/CORRECT AS AT; 14th April 2020 (Version 2).

LAST REVIEWED; 4th Janaury 2022.