1.1 This Policy describes the manner in which Whipsmart Entities (the “We” or “Us”) collect, utilise, and process your personal data in the course of rendering services to our clients (the “Clients”).
1.2 It is imperative that you read this Policy in conjunction with any supplementary privacy policy/notice or fair processing notice that We may furnish on specific occasions when We are engaged in the collection or processing of personal data pertaining to our Clients. This Policy supplements such other policies/notices and Our Terms and Conditions of Business, and does not supersede them.
1.3 We reserve the right to modify the terms of this Policy periodically. This version bears the effective date of 2nd January, 2025.
2.1 The designated data controller responsible for the collection and processing of information provided by Clients in connection with the provision of Our services is the legal entity contracted to render those services. Said entity can be contacted via email at naeem@whipsmart.co.uk.
2.2 We have appointed a dedicated Privacy Officer to address any inquiries concerning this Policy. The Privacy Officer can be reached at the following email address: naeem@whipsmart.co.uk.
3.1 Personal data, or personal information, signifies any information about an individual that can be used to identify that person. It does not encompass data where the identity has been removed (anonymous data).
3.2 We are authorised to collect, utilise, store, and transfer various categories of your personal data as follows:
3.3 We additionally collect, utilise, 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. 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 Policy.
3.4 In the event that you visit Our social media pages or view Our content on social media platforms such as LinkedIn or Facebook, both We and the social media platform provider may collect information about you, including: your social media profile details and user ID, what you say (such as comments) or your actions (such as liking, sharing, or recommending), your country or region (or your precise location if you have provided this in your user profile and you are logged in), your device, and internet connection.
3.5 We may collect 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). We may also collect information about criminal convictions and offences.
4.1 You may furnish Us with your Identity, Contact, and Financial Data by completing forms or by corresponding with Us by post, phone, email, or otherwise. This encompasses personal data you provide when you:
4.2 Other data controllers (including Clients) may also provide your personal data to Us.
5.1 We will only utilise your personal data where the law permits Us to do so, including in the following circumstances:
5.2 Change of Purpose
We will only utilise 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. Should you wish to receive an explanation as to how processing for the new purpose is compatible with the original purpose, please contact Our Privacy Officer at: naeem@whipsmart.co.uk.
5.3 Please note that We may process your personal data without your knowledge or consent where this is required or permitted by law.
6.1 We do not sell, distribute, or otherwise make personal data commercially available to any third party, except as described in this Policy or with your prior permission.
6.2 We may be required to share your personal data with:
7.1 We take the security of the personal data We hold seriously. Policies and procedures are in place to safeguard it from loss, misuse, and improper disclosure.
7.2 We also have procedures in place to address any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.
7.3 All of Our third-party service providers and other Whipsmart Entities are required to implement appropriate security measures to protect your personal information in line with Our policies. We do not permit Our third-party service providers to utilise your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with Our instructions.
7.4 To the extent that the processing of personal data involves the transfer of such data to a territory that does not provide an adequate level of protection, We shall implement appropriate safeguards in accordance with applicable data protection legislation. You may request details of any safeguards implemented from Our Privacy Officer at: naeem@whipsmart.co.uk
8.1 We will only retain your personal data for as long as necessary to fulfil the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period for personal data, We consider:
8.2 If you have opted out of receiving future publications from Us, your contact details will remain on Our opt-out list to prevent you from receiving any further publications from Us.
9.1 We assume responsibility for maintaining an accurate record of personal data once you have submitted the information. Please inform Us of any changes to your information.
9.2 You are entitled to:
9.3 To exercise any of the above rights, please contact Our Privacy Officer at: naeem@whipsmart.co.uk.
9.4 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 expedite Our response.
10.1 Our website utilises cookies. For further information, please refer to Our cookie policy.
11.1 We are not responsible for the privacy policies of third-party websites or social media platforms to which links may be provided via Our website. You should review the privacy policy of the relevant third party before providing any information.
11.2 You may wish to participate in the various social media platforms hosted by Us. However, We do not accept any responsibility for any personal information that you share on such platforms that is subsequently used, misused, or otherwise appropriated by another user.
12.1 If you have concerns about an alleged breach of privacy law or any other regulation by Us, please contact Our Privacy Officer who will ensure that your complaint is investigated.
12.2 You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.
SQB, 77 Marsh Wall, Canary Wharf, London. E14 9SH
+44 207 870 8704
+44 741 154 7219
Info@whipsmart.co.uk