Privacy and Cookie Policy
Version 2.1 - April 2020
1. About this Privacy and Cookie Policy:
Collective IQ Group Ltd. (doing business as, and hereafter known as “Arbolus”) is a company registered in England & Wales(company number 10919514). Arbolus, together with members of our group, “us”, “we” or “our”) are committed tosafeguarding the privacy of third parties with whom we interact, including our Clients, our Expert and third parties who visitany of our websites.This Privacy and Cookie Policy sets out how we collect, and process your personal information gathered from any of ourwebsites and through the other channels. If you provide your information to us either via this website, in person, over thephone or by email (or by other means of electronic communication), you agree to the processing set out in this Privacy andCookie Policy.We may change or update this Privacy and Cookie Policy from time to time without notice and any such changes will takeeffect from the time the revised version is available on this website. We therefore request you periodically to review thisagreement to ensure your understanding of and agreement with the latest requirements.
2. Information we may collect about you:
2.1 Types of data collected
You agree that Collective IQ Group Ltd (“Arbolus”) may collect, retain, and verify information about you. Specifically, typesof data may include:
● Identity Data, including first name, maiden name, last name, username or similar identifier, title, and gender.
● Contact Data, including your address(es), email address(es) and telephone number(s).• Financial Data (if we pay you anything), including bank account details.• Transaction Data, including interactions you may have had with us.
● Technical Data, including internet protocol (IP) address, login data, browser type and version, time zone setting andlocation, browser plug-in types and versions, operating system and platform and other technology on the devicesyou use to access any of our websites.
● Profile Data, including your CV, professional background and career history.• Usage Data, including information about how you use any of our websites, products and services.
● Marketing and Communications Data, including your preferences in receiving marketing from us and third partiesand your communication preferences.We do not intend to collect the following special categories of personal data about you: race / ethnicity, religious /philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health andgenetic biometric data.
2.2 Sources of data
a) Our correspondence (by email, telephone, or other electronic means)
b) Information you provide to us (for example during the registration process including bank details if you are anExpert)
c) Your transactions (transactions carried out through this website and in the fulfilment of services we provide)
d) Website and communication usage (details of your visits to any of our websites and information collected through cookies and other tracking technologies. Such information may include but is not limited to your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data.)
e) Publicly available Data / Data you choose to make public (We may collect Personal Data you manifestly choose to make public including via social media or networking sites such as LinkedIn, or public data from sources such as press releases found through search engines. Such information may include your name, academic and professional background and employment history, including the identities of your current and former employers and job titles/positions.).
3. How we use your personal information:
We may use your personal information in the following ways. In each case, we justify why we use your data in these waysas required under EU data protection laws.In General:
a) For research and development purposes (to understand our business better and develop products and services).Use justification: Legitimate Interests
b) To monitor certain activities such as calls and transactions (in order to ensure service quality and combat fraud).Use Justification: Legal Obligations, Legal Claims, Legitimate Interests
c) To inform you of changes to our services and products.Use Justification: Legitimate Interests
d) To ensure website content is relevant.Use Justification: Legitimate Interests
e) You agree that Arbolus may disclose your information in response to legal process, to protect Arbolus’s or a ArbolusClient’s rights, as otherwise required by law or if pertinent to judicial or governmental investigations, or for the prevention or detection of a crime or fraudulent conduct. If Arbolus sells all or part of its company or enters into a partnership with another business entity, you agree that Arbolus may disclose your information to its new business partners or owners who may then provide you with information about their products and services. Use Justification: Legitimate Interests, Legal Claims, Legal Obligations
If you are an Expert:
a) For research and development purposes (to understand our business better and develop products and services).Use justification: Legitimate Interests
b) To monitor certain activities such as calls and transactions (in order to ensure service quality and combat fraud).Use Justification: Legal Obligations, Legal Claims, Legitimate Interests
c) To inform you of changes to our services and products.Use Justification: Legitimate Interests
d) To ensure website content is relevant.Use Justification: Legitimate Interests
e) You agree that Arbolus may disclose your information in response to legal process, to protect Arbolus’s or a ArbolusClient’s rights, as otherwise required by law or if pertinent to judicial or governmental investigations, or for the prevention or detection of a crime or fraudulent conduct. If Arbolus sells all or part of its company or enters into a partnership with another business entity, you agree that Arbolus may disclose your information to its new business partners or owners who may then provide you with information about their products and services. Use Justification: Legitimate Interests, Legal Claims, Legal Obligations
If you are a Client / prospective Client:
a) You agree that in order to administer our services and carry out our obligations arising from any agreements entered into between you and us, we may occasionally pass your data to third parties (e.g. legal, financial, business or other advisors).Use Justification: Legitimate Interests, Legal Claims, Legal Obligations
b) You agree we may use your data and personal information to provide you with relevant content or marketingmaterials (where you have opted to receive these) in order to optimise our service to you. We will provide an optionto unsubscribe or opt out of further communication on any electronic marketing communication sent to you.Use Justification: Legitimate Interests
c) You accept that we may use your personal data to ensure we collect due payments through the engagement of debt collection agencies or legal advisors.Use Justification: Legitimate Interests, Legal Claims
4. Legal justifications for use of personal information:
Under EU data protection laws, use of personal information must be justified under certain “grounds”.
An explanation of the scope of these grounds can be found below:
Consent: where you have consented to our use of your information (you will have been presented with a consent form inrelation to any such use)
Contract Performance: where your information is necessary to enter into or perform our contract with you
Legal Obligation: where we need to use your information to comply with our legal obligations
Legitimate Interests: where we have a legitimate interest in using your data and our reasons for using it are not outweighedby any adverse impact on your interests, fundamental rights or freedoms
Legal Claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a thirdparty
5. Transmission, storage and security of your personal information:
5.1 Security over the internet
No data transmission over the internet can be guaranteed to be secure from intrusion. We encrypt your information to the highest reasonable professional standards and maintain it in accordance with data protection legislative requirements.
Should you have a password or login, you are responsible for keeping this confidential.
5.2 Storage of data
All data you provide is stored on our subcontractors’ secure servers within the EU.
You agree to Arbolus transferring your information to Arbolus’s European offices, holding such information on its EU baseddatabases, and Arbolus sharing your information with its global subsidiaries and affiliates who may be outside the EU (alist of subsidiaries can be provided upon request).
5.3 Storage / Retention timelines
We will retain your information for as long as necessary for the processing purposes for which they were collected.
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.
5.4 Third Party Links
Our website may contain links to or functionality of third-party websites, plug-ins or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and are not responsible for their privacy policies or data handling procedures.
6. Contacting us and Your Rights:
6.1 Marketing
You have the right to ask us to not to process your personal information for marketing purposes. You can contact us at anytime at privacy@arbolus.com in order to opt out and can also make such requests through unsubscribe links in our emails.
6.2 Your RightsYou have the right to require us to:
a) Provide you with further details on the way we use your information;
b) Provide you with a copy of information that you have provided to us;
c) Update any inaccuracies in the personal information we hold;
d) Delete any personal information that we no longer have a lawful ground to use;
e) Where processing is based on consent, to withdraw your consent so that we stop that particular processing;
f) Object to any processing based on the Legitimate Interests ground unless our reasons for undertaking thatprocessing outweigh any prejudice to your data protection rights.
g) Restrict how we use your information whilst a complaint is being investigated
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention ordetection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we willassess your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office, however we would appreciate the chance to deal with your concern directly in the first instance so please contact us at privacy@arbolus.com as a first step.
6.3 Updating
InformationWe will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in paragraph 6.4 below
6.4 Contacting Us
If you have any questions in relation to this Policy, please contact us at privacy@arbolus.com
6.5 No Fee Required
You will not have to pay any fee(s) in relation to requests to access your personal data. If your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee, or we may refuse to comply with your request.
6.6 Time Limit to respond:
We will endeavour to respond to all legitimate requests within one month of receiving such a request. Occasionally it may take us more than a month if your request is complex or repetitive. In such instances, we will notify you and keep you updated on the progress.
7. Cookies Policy:
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 request 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.
Version 2.1 - April 2020
