Generating Leads and Marketing Communications
At Alumnilab Limited (t/a Whistle), we respect your privacy and are committed to protecting your personal data. This policy sets out how we obtained your Personal Data, and how we look after it and use it, who we share it with and how long we keep it for (Privacy Policy).
This Privacy Policy will also tell you about privacy rights and how the law protects you. If you have any questions about this Privacy Policy or any other matter relating to how we use your personal data, please email us at privacy@whistle.ltd including “DATA PRIVACY REQUEST” as a subject line.
A pdf version of the Privacy Policy can be downloaded here.
1. IMPORTANT INFORMATION AND WHO WE ARE
Who we are
We are Alumnilab Limited (t/a Whistle), a company registered in England and Wales under number 11700744, with our registered office at 201 Haverstock Hill Second Floor C/O FKGB, London, England, NW3 4QG (we or us).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. Any questions about this Privacy Policy should be directed to our data privacy manager using the details set out below:
Contact details
Name: Deborah Tastiel
Email Address: notifications@asserson.co.uk
Where we are a data controller
A data controller, according to applicable data protection laws means a person who determines the purposes for which and the manner in which any personal data is to be processed.
We are a data controller in relation to the personal data that we collect to generate leads, i.e. where we put together a list of individuals whom we believe would like to receive information regarding certain products or services sold by our customers. We may share that personal data with our customers for marketing purposes.
Where we are a data processor
A data processor means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
We are a data processor where we contact individuals on behalf of our customers, using our customers’ marketing lists. These individuals are usually clients of, or prospective clients who wish to receive information from, our customers.
Updates
We keep this Privacy Policy under regular review. This version is dated 14 March 2023. We may update this Privacy Policy from time to time. Any changes we make in the future will be posted on our website www.whistle.ltd (the Website). Please check back regularly to see any updates or changes to this Privacy Policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
2. THE DATA WE COLLECT ABOUT AND HOW WE COLLECT THE DATA
How do we collect personal data
Where we are as a data controller, we collect personal data from publicly available sources, such as:
- Companies House, and similar registrars around the world;
- professional websites of companies – for example, if you work at a law firm, we may find your contact information on the profile made for you by your law firm;
- your professional page or social media account such as LinkedIn;
- technical data from analytics providers, advertising networks and search information providers (e.g. Google);
- businesses that sell databases and personal data for marketing purposes; and
- Your CRM: Whistle tracks and monitors any data relating to sales, sales development and marketing performance in order to ensure that your campaign is performing at the highest level. This includes but is not limited to gathering information on; target contacts, companies, deals, outreach activities and outcomes. This may be done via manual tracking or by third party integrations. Your data is used to monitor and improve performance and is kept confidential.
Where we are a data processor, we do not collect personal data directly but receive it from our customers who have a relationship with the data subjects whose personal data is transferred to us.
What personal data do we process
Whether we are acting as a controller or a processor, we will be processing some or all of the following personal data:
- Identity Data – this includes first and last name, professional title, and name of workplace.
- Contact Data – this includes email address and telephone number.
- Marketing and Communications Data – this includes your preferences in receiving marketing from us and our customers and your communication preferences.
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from personal data but is not considered personal data in law as this data does not directly or indirectly reveal anyone’s identity. For example, we may aggregate personal data to better understand trends and improve our services to our customers. However, if we combine or connect Aggregated Data with personal data so that it can directly or indirectly identify an individual, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Special Categories of Personal Data
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.
3. HOW WE USE PERSONAL DATA
Lawful basis
We only use your personal data when the law allows us to. Where we act as a data controller, we will ensure that we have a lawful basis to process your personal data. Where we act as a data processor for our customers, our customers must ensure that they have a lawful basis to process your personal data, and we rely on our customers’ lawful bases. Most commonly, we use your personal data in the following circumstances:
- where it is necessary for our legitimate interests, or those of our customers, and your interests and fundamental rights do not override those legitimate interests;
- where you have provided consent directly to us or to our customers, and we rely on such consent; or
- where we need to comply with a legal obligation.
Legitimate Interest means the interest of our (or our customers’) business in conducting and managing our business (or in the case of our customers, our customers’ business) to enable us to give you information on the best products or services relevant to you, or to assist our customers in giving you the best services or product. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our (or our customers’) legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. |
Consent means where you have consented to be contacted by us, whether by giving your consent directly to us, or to our customers and you were made aware that your personal data would be used in the way set out in this Privacy Policy. You may revoke your consent at any time by contacting us at privacy@whistle.ltd where you provided us with your personal data directly, or by contacting our customers to whom you gave personal data. If you are unsure who our customers to whom you provided consent are, please check our latest communications where we would have set out who the relevant customers are. |
Legal obligation means that we have to process your personal data in order for us, or our customers, to comply with a legal obligation to which we, or they, are subject to. |
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of the purposes for which we 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 | Type of Data | Lawful Basis |
To generate marketing lists on our or our customers’ behalf | Identity Data Contact Data | Necessary for our legitimate interests (to create marketing leads and provide our services to our customers) |
To form a view on what we think you may want or need, or what may be of interest to you, and to provide you with marketing communications | Identity Data Contact Data Marketing and Communications Preferences | Consent Necessary for our (or our customers’) legitimate interest (to provide you with marketing communications which are relevant to you) |
To contact you to verify your information, and ensure that it is accurate and up to date | Identity Data Contact Data | Necessary for our legitimate interests (to ensure that our leads are valid and accurate) Necessary to comply with a legal obligation |
To contact you to discuss your marketing and communications preferences | Identity Data Contact Data Marketing and Communications Data | Necessary to comply with a legal obligation Necessary for our legitimate interest (to keep our records up to date and understand how individuals prefer to be contacted) |
To notify you about any changes to our Privacy Policy, or respond to any questions you may have | Identity Data Contact Data | Necessary to comply with a legal obligation |
Change of purpose
We will only use personal data for the purposes for which we collected it and, where we act as a data processor as instructed by our customers, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Alternatively you may contact us privacy@whistle.ltd.
4. HOW WE SHARE PERSONAL DATA
Where we act as a data controller, we share your personal data with our customers where we consider that you may be interested or where you have expressed interest in the type of product or service that they offer.
Whether we act as a data controller or data processor, we will share your personal data with our third-party service providers for the purpose of delivering our services to our customers, as well as our professional advisers (including lawyers) as and when required.
Except as set out above, we will not sell, trade, rent or disclose your personal data to others except in the following circumstances:
- if it is required by law enforcement or judicial authorities, or to cooperate with a law enforcement investigation;
- if we have a good faith belief that we are required or permitted to do so by law or legal process;
- to protect our rights, reputation, property or the safety of us or others;
- to defend or enforce our rights or our obligations;
- if the disclosure is required by mandatory professional standards;
- to another third party with your prior consent to do so; or
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 Policy.
We require all our customers, third-party service providers and other third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.
International transfers
We share your personal data with customers, third-party service providers and professional advisors which may be located outside of the United Kingdom or the European Economic Area (EEA), as follows:
- to our lawyers, located in Israel, a country recognised by the UK as providing adequate protection;
- to our customers, wherever they are located, subject to our customers entering into the Addendum to the Standard Contractual Clauses; and
- to our third-party service providers, located in South Africa, Philippines, India, Australia, Israel and the United States, subject to our third-party service providers entering into the Standard Contractual Clauses.
Adequate Protection means that the European Commission has determined, on the basis of Article 45 of the GDPR, that the country which is subject to the adequacy decision, offers an adequate level of data protection. The UK currently follows the European Commission’s decisions on whether a country provides adequate safeguards. The effect of such a decision is that personal data can flow from the UK or the EEA without any further safeguard being necessary. |
Addendum to the Standard Contractual Clauses means the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses for International Data Transfers (also referred to as the Addendum). The Addendum was issued under section 119A of the Data Protection Act 2018, following Parliamentary approval that came into force on 21 March 2022. If there is no adequacy decision about a country or territory, then transfers of personal data need to be subject to appropriate safeguards – these safeguards are legally required to protect people’s rights and freedoms about their personal data. The Addendum allows us to ensure appropriate safeguards are put in place, as the Addendum imposes contractual obligations on the sender and the receiver of the personal data, and grants rights to people whose personal data is transferred. |
5. SECURITY
How we keep your data secure
All personal data collected by or shared with us is stored on our secure servers within the Google Cloud and Microsoft Azure. We use industry standard security and firewalls on our servers.
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 so.
Where we received your data from our customers
Where we have received your personal data from our customers, our customers will act as the data controllers and will have their own privacy policies which will apply to the processing of your personal data by them and by us. We encourage you to read these privacy policies to learn more about their data practices.
6. DATA RETENTION
How long we use your personal data for
We will only retain an individual’s personal data for as long as necessary to fulfil the purpose for which it is collected, 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.
How long we keep anonymised data for
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7. LEGAL RIGHTS
You have the following rights in relation to your personal data:
- Request access to personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove personal information where you have exercised your right to object to processing (see below).
- Object to the processing of personal information 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. You also have the right to object where we process personal information for direct marketing purposes.
- Request restriction of processing of personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
There is no fee to access personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.
What we may need
We may need to request specific information to help us confirm your identity when you make a request. 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 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 may take us longer than a month if the request is particularly complex or a number of requests have been made – but we will always keep you informed.
8. COMPLAINTS
h) If you have any complaints, do not hesitate to reach out to our data privacy manager whose contact details are set out in section 1 above, at the top of this Privacy Policy.
Alternatively, complaints can be made 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 any concerns before any approach is made to the ICO so please contact us in the first instance.
