Tulchan data protection transparency notice for clients, supplier and other third parties.

Tulchan (we) is the trading name of Tulchan Communications LLP, a limited liability partnership registered in England and Wales under number OC353291 with registered office at 85 Fleet Street, London EC4Y 1AE.

1. What is the purpose of this document?

1.1

This transparency notice describes how we collect and use your personal information during and after your relationship with us. In most circumstances, we are a “data controller”, which means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you. However, when we send information about events or press releases to you on behalf of our clients, we are a “data processor” on behalf of our clients. This notice covers both scenarios. If you would like more information about where we are a data processor and who the relevant data controller is in this scenario, please contact us at enquiries@tulchangroup.com.

1.2

This notice applies to users of our website, individuals at clients and suppliers, prospective clients, analysts, investors, political stakeholders, brokers and journalists (you). It is important that you read this notice, together with any other transparency notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. We reserve the right to update this transparency notice at any time and it is up to you to check that you have read the most up-to-date transparency notice.

1.3

If you have any queries about this transparency notice or how we handle your personal information, please contact: enquiries@tulchangroup.com.

2. Third party links

2.1

Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their transparency statements. When you leave our website, we encourage you to read the privacy or transparency notice of every website you visit.

3. How do we collect information about you

3.1

We collect personal information directly from you when you visit our website or communicate with us directly.

3.2

We collect personal information about you indirectly from our clients, suppliers or other market contacts.

3.3

We may collect information about you from public sources, including social media sites such as LinkedIn.

4. What information do we hold?

4.1

We collect, store and use your personal information including: your name; contact details including email address, address, telephone number; job title and location; biographical information; and other information to maintain our relationship with you.

5. What are the legal bases for us to use your personal information?

5.1

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances;

5.1.1

where we need to perform the contract we have entered into with you;

5.1.2

where we need to comply with a legal obligation; and

5.1.3

where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are to ensure the smooth running of our business; providing tailored advice and services to our clients; and managing our relationships with and for our clients.

6. For what purposes do we use your personal information?

6.1 We may use your personal data for the following purpose:

6.1.1

to carry out obligations arising from any contracts between us and you; with clients; with suppliers; or with third parties;

6.1.2

to communicate with you, including to provide you with information or services;

6.1.3

to invite you to events and briefings that we run for our clients;

6.1.4

to put clients in touch with sell-side analysts, investors, brokers or journalists;

6.1.5

where it is necessary for our clients’ business or our business; and

6.1.6

if you browse our website, our analytics tool collects your IP address. We use this to identify the city or country where you are browsing our website to help us learn more about our audiences.

7. Change of purpose

7.1

We only use your personal information 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 need to use your personal information for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so.

7.2

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Data sharing

8.1

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

8.2

Where we share information with other data controllers, they are responsible to you for their use of your information and compliance with the law. We share information with other data controllers as follows: our clients; our suppliers; sell-side analysts, investors, brokers, journalists and our other Group entities (meaning Vox Media Limited (a company registered in England under registration number 05197361 and whose registered address and principal place of business is at 85 Fleet St, London EC4Y 1AE); and Briefcase.news Limited (a company registered in England under registration number 08811304 and whose registered address and principal place of business is at 85 Fleet St, London EC4Y 1AE)); industry professionals; regulatory bodies; and professional advisors.

8.3

We may share your personal data with third party service providers who act on our behalf such as IT services providers. This notice also covers third party service providers we may engage with.

8.4

All our third party service providers and other entities in our group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes.

9. Transferring information outside the EEA and UK

9.1

We may transfer your personal information to our office located outside the EEA and UK in Singapore.

9.2

We only transfer information outside the EEA and UK where we are permitted by law.

9.3

To ensure your personal information does receive an adequate level of protection, we have put in place appropriate measures to ensure that your personal information is treated by those parties in a way that is consistent with and which respects the EU and UK laws on data protection. If you require further information about these protective measures you can request it from enquiries@tulchangroup.com.

10. Data security

10.1

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. We have put in place procedures to deal with any suspected data security breach and will inform you and any applicable regulator of a suspected breach where we are legally required to do so.

11. How long do we use your information for?

11.1

We only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. Your rights in connection with personal information?

12.1

You have the right to object to any use of your personal data which is not necessary for the performance of a contract between you and us, unless we have there are compelling legitimate grounds which override your interests, or we are acting pursuant to a legal obligation. You also have the right to restrict the processing of your personal data (in limited circumstances), access, amend, erase or receive a copy of your personal data in a portable form to the extent permitted by law.

12.2

You have the right to contact a data protection authority if you have unresolved complaints. The UK regulator, the Information Commissioner’s Office, can be found at: ico.org.uk.

12.3

To exercise any of the above rights, please contact enquiries@tulchangroup.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).