The website www.qninepartners.co.uk (our site) is operated by Q Nine Partners Limited. The purpose of our site is to provide you, as a user of our site, with information about us and our services. This Privacy Policy is designed to give you information about how we obtain and process your personal data in connection with your use of our site.
References in this Privacy Policy to “we“, “us” and “our“, are to Q Nine Partners Limited.
We are responsible for deciding how we hold and use personal information about you. We are committed to protecting and respecting your privacy and ensuring that personal and sensitive information is gathered in compliance with this Privacy Policy.
We may collect, use, store and transfer different kinds of personal data about you when you use our site. Examples of when we would collect your personal data, include if you subscribe to receive marketing emails from us or fill in an enquiry form on our site.
Please read this Privacy Policy carefully (together with our Cookies Policy and our site’s Terms and Conditions). From time to time we may also issue other privacy or fair processing notices to you relating to the way in which we collect personal data about you which we will bring to your attention.
Our site is not intended for children and we do not knowingly collect data relating to children.
Our site is operated by Q Nine Partners Limited. Q Nine Partners Limited is a limited company registered in England and Wales under company number 11309930 and has its registered office at The Base, Dallam Lane, Warrington, WA2 7NG (Q Nine).
If you have any questions or concerns about any information contained within our Privacy Policy, please email us at dataprotection@qninepartners.co.uk or telephone us on 01925 625 000.
Personal data, or personal information, means any information relating to an identifiable individual. It does not include any data or information which relates to a person that cannot be identified or where the person’s identity has been removed (i.e. anonymous data).
As a visitor to our site, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Please note, if you visit our business premises, the owner of our business premises may collect, use, store and transfer information about you using CCTV. For further information regarding the CCTV operator’s policy in respect of such data, please contact The Base using the contact details that can be found here.
We may also collect, use 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our site. 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 may also collect other information from you when you visit our site, but which does not personally identify you as an individual and will not be connected with other personal data we hold about you. This may include the following:
We do not 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.
Direct interactions: The majority of the personal data we hold about you is collected when you interact with us or correspond with us directly (via our site, by email, telephone or otherwise). This includes personal data you provide when you:
Automated technologies or interactions: When you interact with our site, our systems will automatically collect information about your equipment, browsing actions and patterns. We collect this personal data (namely Technical and Usage data) by using cookies, server logs and other similar technologies.
We may also receive electronic information about you and your devices (i.e. Technical and Usage data) if you visit other websites employing our cookies. We do this to find out things such as the number of visitors to the various parts of this site. Please see our Cookies Policy and the section headed “Cookies” below for more information.
Other third parties: We may also receive personal data about you from various third parties, as set out below:
We will only collect and process your personal data where we have a legal basis to do so. This legal basis will vary depending on the manner and purpose for which we are collecting your personal information. We will use your personal information as follows:
In most other cases, we will collect and process your personal data where it is necessary for us to do so for our own legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, as detailed below. Our legitimate interests in processing your personal data for our own business purposes which include (without limitation):
We may also process personal data to fulfil our legal, regulatory and risk management obligations, including for the purpose of establishing, exercising or defending legal claims.
Please 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 using the contact details set out in this Privacy Policy if you require further detail about the specific legal ground we are relying on to process your personal data.
Marketing communications from us: We may send you marketing communications by email if you:
Opting out: You can ask us to stop sending you marketing communications at any time, by:
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 we wish 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.
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.
Where we need to collect personal data from you in order to comply with our legal obligations or to perform a contract we have with you and you fail to provide that data when requested, we may not be able to perform the relevant contract (for example, to supply services to you). In this case, we may have to cancel the relevant contract.
We do not sell your personal information to third parties.
We may share your personal data with the following third parties in order to perform a contract with you, comply with a legal obligation or in our legitimate interests of conducting our business:
We require all our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors 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 as set out in our data sharing agreements.
In some instances where we share data with third parties, such as HMRC, those third parties will also be controllers of your data. We shall not be responsible or liable for the way in which other data controllers hold or process your personal data. Please contact those third parties and/or refer to their privacy policies for further information regarding how they will use your data. We shall only share your personal data with third parties in accordance with this Privacy Policy.
We use Google Analytics to help analyse use of our site. This analytical tool uses “Cookies” which are small data files placed on your computer (or other device) to collect standard internet log information and visitor behaviour information. You can find out more about the way cookies work on www.cookiecentral.com and www.allaboutcookies.org. You can find out more about Google Analytic Cookies here.
Our site uses cookies for a number of purposes, for instance to enable us to identify which pages are being used, analyse data about web page traffic, build a demographic profile and improve our site in order to tailor it to client needs. Overall, cookies help us to provide you with a better site, by enabling us to monitor which pages you find useful and which you do not.
For more information about the cookies we use and the reasons why we use them, please see our Cookies Policy.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies (and the above websites tell you how to do this). If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly.
From time to time we may direct you to third party websites through our site. We do not control the content of these third party websites. We encourage you to read the privacy policies for these third party websites before submitting personal information to them. Where these third parties are collecting data on our behalf, your personal data will be transferred to us and used in accordance with this Privacy Policy. Alternatively, if the third party has not been authorised to collect information on our behalf, your personal data will be controlled by that third party, subject to their privacy policy.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
In addition, the personal information you provide to us is only available to our authorised personnel who need access to the information in order to fulfil their duties. They will only process your personal information on our instructions and they shall be subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Once we no longer require your personal information, we will take reasonable steps to destroy it in a secure manner.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
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 requirements. Our retention periods take into account legal and regulatory requirements and are subject to change. If you have any questions in this regard, please contact us using the contact details set out in this Privacy Policy.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in order to develop our business methods and strategy or for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We shall not have any liability whatsoever to you for the deletion of personal data in accordance with our data retention policy.
We do not transfer any personal data outside the European Economic Area (EEA).
You have the following rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):
If you wish to exercise any of the rights set out above in respect of your personal data, please contact us using the contact details set out in this Privacy Policy.
We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above. 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.
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 may refuse to comply with your request in these circumstances.
We will try to respond to all legitimate requests within one month. Occasionally, it may 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.
Please let us know if you are unhappy with how we have used your personal information. You may contact us by email at dataprotection@qninepartners.co.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint.
Please let us know if you change your contact details. You have the right to question any information we hold about you that you think is wrong or incomplete. Please contact us if you want to do this.
| Version | Date |
| 1.0 | 4th March 2019 |