Privacy and Cookies Policy
SEC Newgate S.p.A. is an Italian holding company for communications and marketing businesses and is the data controller of the information collected from you. You can contact SEC Newgate’s Data Protection Contact using the details below. SEC Newgate’s businesses and brands include Publicasity, 21:12 Communications, Redleaf Communications, Newgate Communications, SEC, HIT, Curious Design, Della Silva Communication Consulting, Cambre Associates, Newington, Martis Consulting, Newlink Communications, Kohl PR & Partner and Clai (“the Group”),.
The Group takes the privacy of your information very seriously, and our Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may have been provided to us, collected from publicly available sources or collected through other means such as over email, in person or over the phone.
1. What information we collect about you
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The personal data we process or collect includes:
- your name
- work or home address, email address and/or phone number
- your job title, information about your job role
- your age, ethnicity, gender or nationality
- your occupation, place of employment and work history
- any other information that you may have provided us with or is in the public domain
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
We collect and process data on:
- Business contacts
- Clients and individuals associated with clients
- Persons who supply us with their information
- Shareholders of both our company and that of our clients
- Visitors to our offices
- Visitors to the SEC Newgate and SEC Newgate Group companies’ websites
The activities that we may use data for are:
- Informative emails
- Invitations to events
- Competition entry
- Market Research
- Human Resource activities
- Fund raising
- Managing our relationship with you
- Promoting our business or the business of our clients
SEC Newgate S.p.A. will process personal data for all the time that it is still lawful and valid to do so. SEC Newgate S.p.A. will store the personal data for varying periods, and this will be reviewed at least annually.
2. What basis do we have for processing and collecting your personal data
We only process and/or collect personal data where we have a lawful reason for doing so. The lawful basis for processing and/or collecting personal data by us will be one of the following:
- The processing and or collecting is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
- The processing in necessary in order for us to comply with our legal obligations;
- You have consented to us holding such data for purposes agreed with you; and/or
- The processing or collection is necessary for the pursuit of our legitimate business interests
3. Access to your information and correction
SEC Newgate S.p.A. at your request, can confirm what information we hold about you and how it is processed. If SEC Newgate S.p.A. does hold personal data about you, under certain circumstances you have the following rights:
- the right to ask us to provide you, or a third party, with copies of the Personal Information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
- the right to request erasure, anonymisation or blocking of your Personal Information that is processed in breach of the law;
- the right to object on legitimate grounds to the processing of your Personal Information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why; and
- withdrawal of consent – while we do not generally process Personal Information on the basis of consent when Personal Information is processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Information where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you) or contact the relevant Data Controller as set out below.
To exercise such rights (bar withdrawing from marketing emails – as described above) and if you have any questions about how we collect, store and use Personal Data, then please contact us using the details as set out in the “Data Controller contact information” section below.
Any of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
4. Cookies and websites
Our website uses traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note that if you do this it may prevent you from taking full advantage of the functionality of the website.
5. Sharing data with third parties
We may pass your personal data on to third-party service providers contracted to the Group companies in the course of dealing with you where it is in our legitimate interests to do so to run, grow and develop our business. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service required. When they no longer need your data to fulfil this service, they will dispose of the details in line with SEC Newgate S.p.A.’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so or have another valid legal ground for sharing the personal information.
Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or suppliers.
- in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting our Data Protection Contact using the contact details below at any time.
6. Contact details of the Data Protection Contact / GDPR Owner
SEC Newgate S.p.A.
Sky Light City Tower
50 Basinghall Street
Email – firstname.lastname@example.org
Telephone – 020 7680 6500
7. Updates to this Policy
This Policy was last updated in August 2019. Please check back regularly to keep informed of updates to this Policy.
In the unlikely event that you feel that you need to complain about our use of your personal data, and we have not been able to resolve this internally you have a right to complain to the Information Commissioners Office. Information Commissioner’s Office:
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