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Privacy Policy

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Introduction

Welcome to the Quorum Cyber privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you how we collect personal data for our sales and marketing activities, from our customers and from our website (and any other website linking to this Privacy Policy). It outlines how that personal data is used and tell you about your privacy rights and how the law protects you.

  1. Important information and who we are

Purpose of this privacy policy

Quorum Cyber Security Limited respects your privacy and is committed to protecting your personal data.  This privacy policy aims to give you information on how we collect and process your personal data, tell you about your privacy rights and how the law protects you when:

  • you visit any website operated by us, being quorumcyber.com & clarity.quorumcyber.com (“websites“);
  • you use any of the online tools or services which are available through our websites or sign up to our newsletter or email alerts;
  • purchase any products or services from us as a customer (“Services”);
  • attend any of our events (in person or online); or
  • interact with us through our social media pages on various platforms, including Twitter, LinkedIn

Controller

Quorum Cyber Security Limited, company number SC510322 and with registered office address at 1st Floor Suite (West Wing) Verdant, 2 Redheughs Rigg, South Gyle, Edinburgh, EH12 9DQ, is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have a team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the team using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Compliance Team in the following ways:

Email address: [email protected]

Postal address: 1st Floor Suite (West Wing) Verdant, 2 Redheughs Rigg, South Gyle, Edinburgh, EH12 9DQ

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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 23 March 2023.

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.

Third-party links

Our website may include links to third-party websites, plug-ins or applications.  If you click on those links or enable those connections, it may allow third parties to collect or share data about you. We do not control any third-party websites and are not responsible for their privacy statements. If you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, username or similar identifier, title.
  • Contact Data includes address, email address and telephone numbers.
  • 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, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, Services, your interests, preferences, feedback and survey responses and any support tickets logged in respect of Services.
  • Transaction Data includes details about Services you access from us and details about payments to and from you for those Services (if applicable).
  • Security Event Data: Information Security Event data from Customers including Name, username, email addresses, location, IP addresses, URLs accessed, files accessed, actions taken.
  • Usage Data includes information about how you 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 for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 privacy policy.

We do not knowingly collect any 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). Nor do we collect any information about criminal convictions and offences.

  1. How is your personal data collected?

We use different methods to collect data from and about you including :

  • Direct Interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or completing surveys or otherwise corresponding with us by post, phone, email, through social media or otherwise or attending any events (either in person or online).
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • Joint Events. We sometimes participate in joint events with third parties and where you have opted-in to a joint event, by providing your registration details (name, email & company), we may provide this information to these third parties and vice versa to send you legitimate information about its services and products. You may opt out of this at any time by contacting us. To request that any communications are to stop from the joint partner, you should content the third party direct.
  • Providing Cyber Security Services. In the course of providing Cyber Security products and services to our corporate customers we collect Security Event Data from our customer’s SIEM systems
  • System Monitoring or Support Tickets. To ensure our systems are operating effectively and correctly, we will carry out regular monitoring when providing Services and we may collect Technical Data and Usage Data as part of our monitoring.  Additionally if you submit a support ticket in respect of Service issues, we will collect Identity, Contact, Technical and Usage Data to enable us to respond to your support request.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To respond to any query you make via our website using our Contact Us form (a) Identity

(b) Contact

Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted.

Necessary for our legitimate interest (for running our business, providing our services)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Marketing and  Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(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 advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical

Necessary for our legitimate interests (to study how customers 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, marketing, customer relationships and experiences (a) Technical

(b) Usage

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 make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)
To provide Cyber Security products and services to our corporate customers (a) Identity

(b) Contact

(c) Technical

(d) Security Event

Performance of a contract with our corporate customers

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You may receive marketing communications from us if you (i) have requested email alerts or marketing communications from us, (ii) have consented to marketing communications from us, or (iii) have paid for services from us, and we have assessed that it is in our legitimate interest to send you relevant marketing information that we think you would be interested in, in order to continue to run and grow our business.

If relying on legitimate interest we will always ensure that our interest in doing so has been balanced against any potential impact on you (both positive and negative) and your rights before we process your personal data.  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).

In each case, we will not send any marketing communications if you have asked us to stop contacting you or opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.quorumcyber.com/cookie-policy/.

Change of purpose

We will only use 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the purposes table above.

Third party Detail
External third parties: Service providers, Partner Organisations and Professional Advisors including those who provide:

  • Technical and software services, including software companies and consulting firms who provide support in delivering Services Metrics and analytics.
  • Marketing services

Professional services (provided by such parties as lawyers, auditors, accountants, and insurers)

Corporate partners: includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

Please contact us if you want further information on any sub-processors that may be engaged by us.

  1. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.  Whenever we transfer your personal data out of the UK, we will take steps to ensure a similar degree of protection is afforded to it.

Please contact us if you want further information on any international transfer by us of your personal .

  1. 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do .

  1. Data retention

How long will you use my personal data for?

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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may be able to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a of the personal information 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, out of date or inaccurate 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Review by an independent authority. You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
  • Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

No fee usually required. 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.

What we may need from you. 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.

Time limit to respond. 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.