We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or the Information Commissioner in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Orbital Applied Economics Ltd
Personal data	Any information relating to an identified or identifiable individual
Data subject	The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular services we provide to you. We may collect and use the following personal data about you:

• Your name and contact information, including email address and telephone number and company details;
• Information to check and verify your identity, eg your date of birth;
• Your gender, if you choose to give this to us;
• Location data, if you choose to give this to us;
• Your billing information, transaction and payment card information;
• Your personal or professional interests;
• Your professional online presence, e.g. LinkedIn profile;
• Your contact history and purchase history information to enable us to undertake credit or other financial checks on you, and
• Information about how you use our website, IT, communication and other systems.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email. However, we may also collect information from: publicly accessible sources e.g. Companies House or HM Land Registry; directly from a third party, e.g. credit reference agencies; from a third party with your consent; from website enquiry forms via our IT systems, and through other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• Where you have given consent;
• To comply with our legal and regulatory obligations;
• For the performance of a contract with you or to take steps at your request before entering into a contract; or
• For our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Providing services to you	To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us	For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identityScreening for financial and other sanctions or embargoesOther activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator	To comply with our legal and regulatory obligations
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances:— to comply with our legal and regulatory obligations;— in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information	Depending on the circumstances:— for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;— to comply with our legal and regulatory obligations
Preventing unauthorised access and modifications to systems	Depending on the circumstances:— for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;— to comply with our legal and regulatory obligations
Protecting the security of systems and data used to provide the goods and services	To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Updating and enhancing customer records	Depending on the circumstances:— to perform our contract with you or to take steps at your request before entering into a contract;— to comply with our legal and regulatory obligations;— for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances:— to comply with our legal and regulatory obligations;— for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Credit reference checks via external credit reference agencies	For our legitimate interests, i.e. to ensure our customers are likely to be able to pay for our products and services

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• Contacting us at matt.georges@orbitaleconomics.com, or
• Using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts;

Who we share your personal data with

We may sometimes share personal data with our banks and with third parties we use to help deliver our services to you and to help us run our business, e.g. marketing agencies or website hosts.

We or the third parties mentioned above occasionally also share personal data with:

• Our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations, and
• Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. Usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

If we are no longer providing services to you, we will delete or anonymise your account data after seven years.

Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

If it is necessary for us to transfer your personal data to countries outside the UK we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

• In the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
• There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• A specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object:— at any time to your personal data being processed for direct marketing (including profiling);— in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please:

• Email or write to us — see ‘How to contact us’ below;
• Provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
• Let us know what right you want to exercise and the information to which your request relates.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see ‘How to contact us’ below). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner

The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy notice from time to time. When we do we will publish the new version on our website.

How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details
Orbital Applied Economics The Boathouse Design Studio, 27 Ferry Road, Teddington, Middlesex TW11 9NN matt.georges@orbitaleconomics.com