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Privacy Policy

Table of Contents

Introduction

This Privacy Policy is designed to set out the obligations we have to clients and prospective customers (otherwise known as ‘data subjects’), with regards to the safeguarding of their personal information. In compiling this Policy, this document also provides guidance about the way we use ‘Personally Identifiable Information’ (PII) to provide a route into and through our contracted services, using any of our designated communications channels e.g., email, our website platforms and other digital content, such as our advertised social media channels.

Services & Privacy

We offer strategic advice and insight to businesses and their management teams across a broad range of specific areas within Operations, Technology and Human Capital. To fulfil our obligations and provide a route into our services we retain PII details of those individuals requesting information from us. This will always include basic contact details such as: Title / Name / Job Title / Company Name / Address / Telephone numbers and Email addresses. It may also include remuneration details dependant on any authorised contractual agreement with our client. For example, we might use the information about staff remuneration in order to make recommendations about salary structures, incentive schemes and hierarchy. We may also refer to personal data in the public domain, although this data is not stored or retained across our systems.

Any data we process against EU citizens will be securely stored in accordance with both UK and EU data privacy legislation; any personal data processed against UK citizens will be securely stored in accordance with UK privacy legislation e.g., the Data Protection Act 2018 and the Privacy & Electronic Communications Act 2019 (see below).

Data Protection Act 2018 / Privacy & Electronic Communications Regs 2019

This Privacy Policy is designed to communicate the methods, safeguards, actions, rights and lawful obligations Genesis DM Limited (GDML) has to any of its ‘Data Subjects’ under the General Data Protection Regulation / Data Protection Act (2018) and the Privacy & Electronic Communications Regulations, to personal data used by Genesis DM Limited (GDML). This document aims to provide full transparency around the processes we use to gather and store personal data and how we use it to communicate with any given ‘Data Subject’. Our commitment to the personal rights and freedoms of those ‘data subjects’, who may during the course of our business activities receive an approach from an officer of the GDML, is of our utmost concern.

Under UK (& EU) privacy laws, companies are entitled to rightfully create commercial opportunities as long as they abide by the various Regulations, which dictate that companies must provide clear opportunities for all ‘Data Subjects’ to make clear their request for privacy, and to maintain that request until such times as the ‘Data Subject’ chooses otherwise.

As a provider of business-to-business services we have a ‘Legitimate Interest’ to offer these services to ‘Data Subjects’ where we believe there could be a mutual interest for a commercial engagement between both parties. However, we agree to cease communications with any ‘Data Subject’ where they believe (or they have communicated to us either verbally or in writing) that our offer of service is no longer valid. Should ‘data subjects’ not make their feelings clear about communications from GDML, we are required to determine the relevancy and suitability and cease further contact after a reasonable period of engagement. Consequently, GDML will conform to UK (and or European) Law and will not unlawfully use the personal data of any individual beyond a period where it has become clear that individual does not wish to engage with GDML. Furthermore, GDML will further uphold its prospect’s rights to privacy by suppressing commercial telephone data against the CTPS (Corporate Telephone Preference Service).

Using suppression files GDML will record the associated actions or non-actions of individuals, so that the Company will continue to conform and safeguard the personal rights of each ‘data subject’, namely through various suppression files that prevent any further dialogue, written or oral.

How we use your information

This Privacy Policy explains what you can expect when we collect and process your PII (e.g., business related data). The legal basis for this is our legitimate interest, namely the business administration and the performance or creation of a contract between you and us, or the declaration of your personal data (for endorsements etc) which may appear on our website. However, in the case of the latter of these they will only appear in the public domain once we have received express permission from you to publish it.

For employment-related personal data, the legal basis for this is also a matter for our legitimate interests, namely the protection and assertion of legal rights and/or the performance or creation of a service delivered between your employer and us for improvements in their overall service.

‍‍Should we decide to process any personal data for a purpose other than that for which it was collected, we will provide you with information on that other purpose and with any relevant further information prior to any further processing.

All PII data we collect is stored within the UK on our UK hosted servers.

Governing Law

You irrevocably agree that UK courts of law shall have exclusive jurisdiction to resolve any dispute or claim of whatever nature arising out of or relating to this website and that UK law will govern such dispute or claim should this be necessary. GDML makes no claim that information contained in this website is appropriate for use in any province or country other than the UK and you hereby agree that GDML will have no responsibility in respect of access to the website from provinces or countries whose domestic laws prohibit such access. Those who chose to access this site outside the UK do so largely at their own risk/cost. However, any data supplied by non-UK persons, will only be stored if deemed relevant to both parties, at which point it would be covered by the laws of the data subject’s country.

Copyright and Use

GDML owns the copyright across all the content published on our website(s) and across any other in-house channel except where others have been credited as the originating source.

All content on this website is governed by UK copyright law, however, you are welcome to use the content if you agree to credit the source of the selected data, either in part or whole, or by first obtaining written permission from the author/company. All other use is strictly prohibited.

Trademarks

The display of any trade names or trademarks within this website does not imply that any licence has been granted to any third party in respect of the same.

Website Visitors

When someone visits our website, we collect standard internet log data surrounding visitor behaviour patterns. We do this to track the performance and validity of our site and to enable us to make relevant future endorsements and improvements. This information is anonymous data gathered through Google Analytics, and as such is unable to identify any individual or compromise personal data.

In order to provide you with our products and services, or to reply to any enquiries, we collect professional information (e.g., business related data) about you and your company submitted to our websites, passed on during telephone conversations, included in emails and mobile messaging and any other form of written or verbal communication.

We may also hold the business IP addresses of visitors to our website but as this is not PII because it cannot be attributed to any one single data subject.

We will store this data for a period of up to 24 months of inactivity prior to deletion.

Cookies

A cookie is a small file which is saved on your phone, tablet or computer when you visit our website. We use cookies so that we may provide you with a better service/experience. Generally, most user data collected from our website through a ‘Cookie’ is processed anonymously, other than when you are asked to provide your contact details to upload information from or upload information to our site. Any personal information which is submitted by a user in the course of using the website will be safeguarded under UK data privacy laws (as mentioned previously).

The cookies which GDML use most often improve the functionality of our site and therefore improve the user experience or allow forms to be used for keeping track of the information you enter prior to transmission. Beyond this, you may from time to time see embedded YouTube videos on our site(s) that depict elements of our work. If we can see any of these videos embedded, then we will always use YouTube’s ‘Privacy Enhanced’ mode. This means that YouTube won’t store information about visitors to the pages on our site unless visitors interact with those videos.

When you visit our website(s), we make it clear that your continued use of the site will be deemed as your consent. A notice to this effect is made sufficiently visible to avoid any ambiguities. You can of course simply press ‘Accept’. Should you choose to review the Cookies that we actively embed, you will be referred to this document to review the full and up-to-date list.

In using our website, you consent to the GDML collecting basic analytical information about your anonymous interests in our services, pages and duration on site. You also consent to GDML using this analytical information for its operational purposes in accordance with the terms set out in this Policy.

The cookies we use are there solely to improve the whole website experience for you (our site visitors) and for us (through non-personally identifiable statistics data). They fall into three categories: ‘Necessary’, ‘Preference’ & ‘Statistics’ cookies.

Necessary Function Cookies

These essential cookies do things like help make a website usable by enabling basic functions like page navigation and remembering your progress through a form e.g., a request to download/upload information. They always need to be on to fulfil any request you may have and to allow the website to function properly. Any forms that are sent through the website are removed from the web server, only residing on local devices after transmission/upload.
Cookie Name Provider Type Purpose Expiry
_grecaptcha google.com HTML This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. Persistent
rc::a google.com HTML This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. Persistent
rc::b google.com HTML This cookie is used to distinguish between humans and bots. Session
rc::c google.com HTML This cookie is used to distinguish between humans and bots. Session
VISITOR_INFO1_LIVE youtube.com HTTP Estimates the users’ bandwidth on pages with integrated YouTube videos to provide an optimal player interface. This information is shared with YouTube. 6-8 months
elementor genesisdm.co.uk HTML Used in context with the website’s WordPress theme. The cookie allows us as the website owner to implement or change the website’s content in real-time. Persistent

Preference Cookies

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. Other purposes like those referenced below relate to specific user interactions within a third-party asset, such as YouTube.
Cookie Name Provider Type Purpose Expiry
yt.innertube::nextId YouTube HTML Stores information about the video shown after the current video has been viewed. Persistent
yt.innertube::requests YouTube HTML Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Persistent
yt-remote-cast-installed YouTube HTML Stores the user’s video player preferences using embedded YouTube video. Session
yt-remote-connected-devices YouTube HTML Stores the user’s video player preferences using embedded YouTube video. This information is shared with YouTube. Persistent
yt-remote-device-id YouTube HTML Stores the user’s video player preferences using embedded YouTube video. This information is shared with YouTube. Persistent
yt-remote-fast-check-period YouTube HTML Stores the user’s video player preferences using embedded YouTube video. This information is shared with YouTube. Session
yt-remote-session-app YouTube HTML Stores the user’s video player preferences using embedded YouTube video. This information is shared with YouTube. Session
yt-remote-session-name YouTube HTML Stores information about which YouTube interface is being used. This information is shared with YouTube. Session

Statistics Cookies

Statistic cookies help us understand how visitors interact with our website(s) by collecting and reporting information anonymously. We use Google Analytics to measure how you use the website so we can improve it based on user needs.

Cookie NameProviderTypePurposeExpiry
_gaGoogle AnalyticsHTTP CookieRegisters a unique ID that is used to generate statistical data on how the visitor uses the web site. This information is also shared with Google.2 years
_gatGoogle AnalyticsHTTP CookieUsed by Google Analytics to throttle request rate. This cookie does not store any information.1 day
_gidGoogle AnalyticsHTTP CookieRegisters a unique ID that is used to generate statistical data on how the visitor uses the web site.1 day
YSCyoutube.comHTTPRegisters a unique ID to keep statistics of what videos from YouTube the user has seen.Session

Cookie Settings

Your rights

Under the Data Protection Act 2018, GDPR and the PECR 2019, you have rights as an individual to access the information we hold about you, namely:-

  • The right to be informed; where and how we have processed your personal data
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object

You can pursue this through a ‘Subject Access Request’ (SAR), or a Right to be Forgotten (RTBF) which you can instigate by writing to our ‘Data Controller’ at the address shown at the end of this document or by email to datacontroller@genesisdm.co.uk stating the reason for your request.

Disclosure of Personal Information

Generally, we will not disclose personal data to third parties not listed in this Policy without your consent. However, there may be circumstances where we can pass on personal data without consent, for example, to prevent and detect crime and to produce anonymised statistics.

General Email

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us meets UK law.

Complaints or queries

Should you ever feel the need to complain to us you can be assured that we will deal with such matters with care and integrity and in a timely fashion (as prescribed under GDPR). Any such complaints will be recorded and used to acknowledge your concern and to bring the matter to an appropriate conclusion.

We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for twenty-four months following case closure.

If you want to make a complaint to the ICO (the statutory body which oversees data protection law for all UK citizens) about the way we have processed your personal information, you can contact the ICO here. GDML has been registered with the ICO (Registration No. Z9575644) for the processing of personal data, since September 2006.

Links to other websites

This Privacy Policy does not cover the links within this site linking to other websites or your decision to visit them. We therefore encourage you to read the privacy statements on the other websites you choose to visit about how they handle your PII.

Changes to this Privacy Policy

As data privacy regulations are updated or we need to amend our internal processes to reflect them we will continue to update this Policy so that it remains relevant for all parties.

Contact Us

To contact us in writing please address your correspondence to:-

The Data Controller
Genesis DM Ltd
The Dairy, Buckwell Lane
Clifton-upon-Dunsmore
Rugby
CV23 0BJ

Or email, datacontroller@genesisdm.co.uk

Last updated: November 2021

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