Version 3.0- July 2024
1. IMPORTANT INFORMATION AND WHO WE ARE
Privacy Policy
This privacy policy gives you information about how Arbolus collects and uses your personal data through your use of this website and associated websites and your interactions with us, including any data you may provide when you register with us, sign up to our newsletter or purchase a product or service.
Arbolus (Group) is made up of different legal entities, namely Collective IQ Group Limited, Arbolus Technologies Spain S.L., Arbolus US, Inc., and Arbolus Technologies India Private Ltd. This privacy policy is issued on behalf of the Group so when we mention the "Company", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. Collective IQ Group Limited, a company registered in England & Wales (company number 10919514), is the controller and responsible for this website.
If you use our websites or provide your information to us, you agree to the processing set out in this Privacy Policy.
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
● Identity Data includes your first name, last name, username or similar identifier, title, and, if you are a consultant, your photograph and date of birth (if provided).
● Contact Data includes your correspondence and billing addresses, email address(es) and telephone numbers.
● Financial Data includes your bank account and payment card details, payment method, date and amount and any invoice details (as applicable).
● Transaction Data includes details about payments to and from you.
● Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
● Profile Data includes your username and password and, if you are a consultant, your CV (if provided to us), professional background, social media links, career history, education, profiling information (including any responses to our screening questions such information pertaining to your experience and expertise and from being a customer or user of certain products), website requests made by you, your preferences, feedback, responses (including any views and opinions that you choose to send to us, or publicly post about us on social media platforms) and information about your engagements.
● Usage Data includes information about how you interact with and use our website, products and services.
● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We do not collect the following special categories of personal data about you: race, ethnicity, religious and philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic biometric data.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
● Your interactions with us. You may give us your personal data by filling in online forms (including surveys) or by corresponding with us by post, telephone, email or otherwise. We may also create personal data about you, such as records of your interactions with us and our clients.
● Automated technologies or interactions. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
● Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data is collected from analytics providers, advertising networks, and search information providers.
If you are a consultant
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Tipalti, our payment provider.
Identity, Contact Data and Profile Data is collected from publicly available sources (e.g., LinkedIn), data brokers, credit rating agencies, law enforcement agencies or aggregators.
4. HOW WE USE YOUR PERSONAL DATA
LEGAL BASIS
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
● Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
● Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. 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)
● Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
● Legal claims: We may use your personal data when we need to defend, prosecute or make a claim against you, us or a third party (as applicable).
● Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you would like to be engaged by one of our clients for a consultation or survey or to subscribe to an email newsletter.
If you provide personal data to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.
PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose / Use
Legal basis
To register you as a new user
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Dealing with your requests, complaints and queries
(a) Consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to study how you use our products/
services, to develop them and grow our business)
To enable you to partake in consultations
(a) Consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to study how you use different products and services so that we can grow our business)
To enable you to partake in consumer data surveys
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how you use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products / services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data
Necessary for our legitimate interests (to carry out direct marketing, develop our products /services and grow our business) and consent, having obtained your prior consent to receiving direct marketing communications.
To carry out market research through your voluntary participation in surveys
Necessary for our legitimate interests (to study how you use our products / services and to help us improve and develop our products and services).
5. DIRECT MARKETING
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
6. THIRD-PARTY MARKETING
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
7. OPTING OUT OF MARKETING
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at marketing@arbolus.com.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
8. COOKIES
Arbolus Group uses Cookies on all our websites. Cookies are text only strings of characters identifying a visitor's browser when you visit any of our websites. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set.
Arbolus records every visit to its websites and logs web requests and internet protocol address information. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly.
9. DISCLOSURES OF YOUR PERSONAL DATA
Generally
We are allowed to disclose your personal information in the following cases:
● If we decide to sell our business or any specific assets, we can disclose it to the potential buyer.
● We can disclose it to other businesses within Arbolus Group.
● We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
● We can exchange information with others to protect against fraud, money laundering, bribery, insider trading or credit risks.
● Where any of your data is required to be shared with a third party, we will take reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under data protection legislation.
● We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
● We may contract with third parties to supply services to you on our behalf such as payment processing, search engine facilities, background checks, advertising and marketing. In some cases, the third parties may require access to some or all of your personal information that we hold. The details of these third parties may be provided to you on written request. Please see our contact details listed below.
If you are a consultant
● By registering and agreeing to this Privacy Policy, you consent to us sharing your name, profile photograph, employment history, geographical location, social media profile, details of your current occupation/role, profiling information (such as your responses to any screening questions or surveys), information shared via chat and any transcript(s) and recording(s) of your consultation(s) within Arbolus Group and with the specific client who wishes to engage you or has engaged you.
You acknowledge that our platform may be accessed by all our clients globally who have licensed access but the content of the consultation (including any associated recordings and transcripts) will only be available to the particular client (including its employees, contractors and end clients) who had requested to engage you and to whom we have certain confidentiality obligations which may prevent us from disclosing their identity.
Our clients will all have contractually agreed not to share, distribute or otherwise provide access to that content to anyone who is not a licensed user. However, we do not guarantee their compliance with, and cannot be held liable for any non-compliance in respect of, that contractual obligation.
Our clients and we may also share your name and biographical information publicly in connection with your consultation(s), but only with your specific written consent.
10. INTERNATIONAL TRANSFERS
If you are a user in the UK or EEA, note that because our business is international we may need to transfer your personal information to third parties and also to other members of the Arbolus Group which includes our legal entities in Spain, the USA and India. Your data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) or UK in which data protection laws may be of a lower standard than in the EEA or UK.
If we do store or transfer data outside the UK or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR or in the EEA under GDPR, as the case may be.
Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In respect of other countries, we will transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities (or if the information is already publicly accessible there).
Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK and/or EEA if it is necessary for us to do so.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
12. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about you (including Contact, Identity, Financial and Transaction Data) for six years after you cease being a Platform user for tax and financial auditing purposes.
In some circumstances you can ask us to delete your data. Please see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
13. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data. Specifically, you have the right to:
● Request access to 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 correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data in certain circumstances. 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 processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
● You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing for details of how to object to receiving direct marketing communications).
● Request the transfer of 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.
● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
● If you want us to establish the data's accuracy;
● Where our use of the data is unlawful but you do not want us to erase it;
● 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
● You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us at Privacy@arbolus.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at Privacy@arbolus.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 in the first instance.
14. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on 29 July 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
15. THIRD-PARTY LINKS
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Version 3.0 - July 2024
