Charles Square Privacy Policy

Privacy Notice

Charles Square Limited with offices in London and Hertfordshire collectively known as “CSq”.

What is the purpose of this privacy notice?
This privacy notice details what personal information we may collect, process and store about our Clients in order to adhere to EU Data Protection Directive 95/46/EC (“GDPR”) and other local regulatory authorities. “Personal Information” means any information relating to an identified or identifiable natural person (‘data subject’).

How do we process your personal Data?
CSq is a Technology Service Partner to its Clients. In our capacity as a service provider, we will receive, store, and/or process personal data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or clients. The information that we collect from our clients in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the client.

CSq uses personal data that it collects directly from its clients in its role as a service provider for the following business purposes, without limitation:

  • Maintaining and supporting its products/services, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including operations related to providing services to a client);
  • Satisfying governmental reporting, tax, and other requirements;
  • Storing and processing data, including personal data, in computer databases and servers located in the United States, EMEA and Asia;
  • Verifying identity (e.g., for access to accounts or for service desk support) as requested by a client;
  • For other business-related purposes permitted or required under applicable local law and regulation; and as otherwise required by law.

We rely on the following lawful bases for processing your data:

  • In the performance of a contract - This means we process your data where it is necessary for the performance of a contract with you, or to take steps, at your request, before entering into such a contract.
  • With legitimate interests – Whenever we use this lawful basis, we believe the processing we’re undertaking is something you would reasonably expect us to do. You have the right to object to this processing if you do not agree. To do this please contact us.
  • To comply with a legal or regulatory obligation – this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.

CSq does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.

In regard to users of our website we use the data we collect from you to:

  • To improve and enhance our website
  • To respond to your enquiry

We rely on the following lawful bases for processing your data:

  • With legitimate interests – whenever we use this lawful basis, we believe the processing we’re undertaking is something you would reasonably expect us to do. You have the right to object to this processing if you do not agree. To do this please contact us.

If you apply for job with us, we use the data we collect from you to:

  • To assess your suitability for a particular job role
  • To ensure we are complying with our legal obligations as an employer

We rely on the following lawful bases for processing your data:

  • In the performance of a contract - This means we process your data where it is necessary for the performance of a contract with you, or to take steps, at your request, before entering into such a contract.
  • To comply with a legal or regulatory obligation – this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.

What Data do we Collect?
CSq has identified the following Data Fields as potentially collected on the basis of providing Contractual Services to its clients and their members of staff:

Data Fields – Personal Data Information

  • first name
  • last name
  • email – work
  • email – personal
  • address – work
  • address – home
  • ip address – lan
  • ip address – wan
  • phone number – work
  • phone number – home
  • mobile phone number – work
  • mobile phone number – home
  • mobile phone imei – work
  • mobile phone imei – home
  • online forum/website/software account username(s)

CSq has also identified the following Data Fields as potentially collected to send further information to website visitors:

  • first name
  • last name
  • company name
  • email
  • phone number
  • ip address
  • browser type

What do we do with it?
CSq complies with its obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

How long will we keep it?
CSq only retain the personal data in accordance with contractual or regulation requirements.

Your Rights in connection with Personal Data

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

You have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
  • The right to access the personal data we hold about you. The section below ‘How can I access my personal data?’ will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in the section ‘Contact Details at CSq’.
  • The right to erasure, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. This only applies in certain circumstances. Please contact us using the details in the section ‘How do I Contact you?’.
  • The right to restrict (i.e. prevent) the processing of your personal data in certain circumstances.
  • The right to object to us using your personal data for a particular purpose or purposes. This right only applies if we are processing your information because the process is in our legitimate interests.
  • The right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.  If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown below.  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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Contact Details at CSq
For all queries, complaints or to review your rights and information we have on file, please contact us at info@charlessq.co.uk or by writing to Data Protection, Charles Square Limited, 22–23 Little Portland Street, London, W1W 8BU.

Contact Details at the ICO
You can also contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF to assist you with any queries regarding your rights under GDPR.

Changes to Privacy Notice
Changes may be necessary to this privacy notice to reflect legal or data processing developments. The revised Privacy Notice will be posted on this website.

Version: 1.0

Date: 20.09.2019