Privacy Policy

SEPAR International Ltd registered in England under registration number 11073297. SEPAR International Ltd registered address is Kemble House, Broad Street, Hereford, HR4 9AR and operates the website www.separinternational.com (the "Site") and organises its maintenance and the placing of its content.

SEPAR International Ltd understands that privacy is important and is committed to respecting your privacy and protecting your personal data. This policy sets out SEPAR International Ltd approach to the collection, storage, usage and transfer or disclosure of information you provide to us and information we collect in the course of operating our business or in connection with this Site. It also includes a description of your data protection rights which, in some instances, will include a right to object to the processing we carry out.

For any enquiries relating to this Privacy Policy or data protection at SEPAR International Ltd generally, please contact info@separinternational.com.

Information we collect

SEPAR International Ltd collects, receives, stores and processes the following information: 

• information that you provide when using the Site;
• information you provide when applying for a job with SEPAR International Ltd which includes the information you provide within any application or CV submitted to SEPAR International Ltd;  
• information necessary to perform services requested by you including contact details necessary for client relationship management;
• information necessary to fulfil the terms of our contracts;
• any information you provide when subscribing to any marketing or mailing services; and
• information contained in, or relating to, any communications you send to us or send through the Site (including the communication content and meta data associated with the communication). 

 Information supplied for the above purposes may include names, addresses, telephone numbers, email addresses, dates of birth, educational details, and any other additional information that you may supply, or which may be otherwise processed. 

Our Site’s data collection forms use cookies for more information please see our Cookies Policy.

Use of Data

SEPAR International Ltd is the controller of any personal data where we determine the means and method of the processing, for example any personal data collected through the Site, or for any marketing or client relationship management purposes, or where the personal data is used for compliance with our own internal procedures or legal and regulatory requirements. Additionally, SEPAR International Ltd may process personal data as a data processor upon the instructions of you or a third party. 

SEPAR International Ltd processes all personal data in accordance with applicable data protection law including the EU General Data Protection Regulation 2016/679, as incorporated into UK legislation ("GDPR"). 

SEPAR International Ltd will use personal data for various purposes which include:  

• to provide our services to you; 
• to maintain our business relationship, where you are a user of the Site, a client or a recruitment candidate, including for ongoing correspondence; 
• to provide you with information that you have specifically requested;

• to deal with enquiries and complaints made by or about you relating to us or the Site;
• to keep the Site and systems secure and prevent fraud; 
• where relevant, to fulfil our contractual obligations;
• where relevant, to meet legal, regulatory and compliance (including internal compliance) requirements;
• where relevant, for the establishment, exercise or defence of legal claims;
• to protect the rights, property, or safety of SEPAR International Ltd, our clients, or others;
• to administer the Site;
• to understand your interests and preferences so we can tailor the content, see our Cookie Policy; and
• to compile anonymous statistical data about the use of the Site to improve its content and usability.

SEPAR International Ltd ensures that all transfers from the UK or the EU to third parties located in non-equivalent jurisdictions are subject to adequate safeguards and the protections required under applicable law.

The Legal Basis for Processing Personal Data

SEPAR International Ltd processes personal data on the following legal basis:  

a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing service(s) to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;  

b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data.   We may also be obliged by law or for national security reasons to disclose your personal data to a regulatory body, government agency, court of competent jurisdiction, regulatory body or law enforcement agency in response to a lawful request submitted by court order, subpoena, warrant, or similar legal mechanism that carries equal weight;

c) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected.  Our legitimate interests include responding to requests and enquiries from you or a third party, maintaining client relationships, optimizing our website and customer experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner;

d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way. To the extent that we are processing your personal data based on your consent, you will have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section at the bottom of this page. 

Security

The security and protection of personal data is of the highest importance and concern to SEPAR International Ltd. We have in place all generally accepted standards of technology and operational security in order to protect personal data processed by us from loss, misuse, alteration or destruction and to ensure compliance with the requirements of all applicable data protection and privacy legislation. 

Notwithstanding the arrangements set out above, unfortunately the transmission of information via the internet is not completely secure. Once we have received information, we will use strict procedures and security features to try to prevent unauthorized access.

Data Subject’s rights

You have certain rights in relation to personal data we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

Right of Access

You have the right at any time to ask us for a copy of your personal data that we hold.  Where we have good reason, and if the GDPR or other applicable data protection law permits, we can refuse your request for a copy of your personal data, or certain elements of the request (for example, if we would also be disclosing third party personal data). If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or Completion

If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. Therefore, please advise us of any changes to your information. You can let us know by contacting us using the details in the Contacts section at the bottom of this page.

Right of Erasure

In certain circumstances, you have the right to request that personal data we hold about you is erased e.g., if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent (which you wish to withdraw) and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal data by contacting us using the details in the Contacts section at the bottom of this page.

Specifically, please note that you have the right to object:

(a) at any time to SEPAR International Ltd use of your personal data for direct marketing purposes; and
(b) to SEPAR International Ltd processing of your personal data where it is based on our legitimate interests, unless we have compelling legitimate grounds to process the information, or we need to do so in relation to legal claims.
You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. 

You can ask us to transmit that information to you or directly to a third-party organization. 

The above right exists only in respect of personal data that:

• you have provided to us previously; and
• is processed by us using automated means.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section at the bottom of this page.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights. 

Disclosure of Personal Data to Third Parties

SEPAR International Ltd will not share your personal data with third parties unless required by law, required to enable the fulfilment of the purpose for which the personal data was originally supplied or as otherwise set out in this policy. SEPAR International Ltd may transfer all or part of its business in the circumstances of a merger or sale of part or all of its business. In such circumstances personal data may be transferred but this will be only in circumstances where the acquiring company has agreed to the same standards and terms of privacy as are set out in this policy. SEPAR International Ltd remains liable to you in respect of its obligations concerning your personal data in cases of onward transfers to third parties.

Complaints

If you are unhappy about our use of your personal data, you can contact us using the details in the Contact section at the bottom of this page. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/ 

Post: Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Data Processed During Provision of Services

This Privacy Policy primarily relates to personal data collected and processed as a result of operating our business or your interaction with the Site. However, in the course of providing our services (including but not limited to due diligence services, cyber security services, and other forensic investigation or threat analysis services) to clients, we may process personal data on individuals who are the subject of, or relevant to, those services.  

In accordance with GDPR or other applicable data protection laws, where we are a controller of the personal data in relation to due diligence services, we do not provide fair processing notices to such individuals as to do so would seriously impair the achievement of the objectives of that processing.  We treat all such data in accordance with our obligations under GDPR or other applicable data protection laws.  We make this statement in compliance with our obligation under article 14(5)(b) GDPR to publicize that nature of the information that would otherwise be contained in any such fair processing notice.

Personal data obtained and processed in the course of providing client services will typically include a summary of the individual’s profile or reputation in the market.  

The data will be collected for the purpose of providing our services to our clients.  The lawful basis under GDPR, or analogous data protection laws, for such data processing will vary depending on the nature of the data and the project, but will include:

a) necessary for the purpose of our or our client’s legitimate interests. These interests may include ensuring that the client does not take actions that could result in legal liability, reputational impact or other adverse effects;

b) necessary for the prevention or detection of an unlawful act;

c) necessary for the establishment, exercise or defence of a legal claim;

d) where it is in the vital interest of the data subject or a third party;

e) the data has been manifestly made public by the data subject.

We are a controller of personal data which is collected through source enquiries with suitable individuals. We are a processor of personal data which is collected through open-source research, which includes public record (such as press articles, corporate filings, court records, and the records of central and local government departments and statutory bodies), news aggregators, specialist databases, social media and deep-web research.

Individuals whose data is processed during the course of our client services have the same rights as all other data subjects and personal data processed in this manner is subject to the same safeguards as set-out in applicable law and this Privacy Policy. Please see above for details, and the Contact section below for details of how to exercise your rights. 

Retention

Personal data is stored according to our global data retention and data protection policies. Our policies establish that personal data is stored no longer than is necessary for the purposes for which it was processed.

We may nevertheless retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person.

Changes to our Privacy Policy

This Privacy Policy is subject to changes, amendments, or may be supplemented from time to time. New versions will be published on our website and will be effective immediately upon publication. Changes may also be communicated via email. Please check this page occasionally to see any updates or changes.

Contact

If you have any enquires or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us by using one of the methods listed below.

When you contact us, we will ask you to verify your identity.

Email: info@separinternational.com