1.1 This privacy notice (the “Privacy Notice”) explains our approach to our processing of your personal data which is any information relating to you (including by reference to identifiers associated with you or any device that you use to access our website) in connection with the provision of visit www.chartr.co (“Website”) and/or the provision of our newsletter and related services including those that we make available via this Website (“Service”).
1.2 Please take a moment to read this Privacy Notice as it provides you with important information about your personal data, including the rights you have in relation to it.
1.3 We will use reasonable endeavours to ensure that any changes we make to this Privacy Notice in the future will be posted on the Website and, where we have collected the relevant contact details, notified to you by email. Please check this page frequently to see any updates or changes to our Privacy Notice.
2. 1 The Website and our Service is owned and operated by Chartr Limited (“we”, "us”, “our”), an English company (No. 12034385) with its registered office at 231 Vauxhall Bridge Road, London, United Kingdom, SW1V 1AD. We are registered as a controller with the Information Commissioner’s Office (Registration No: ZB400199).
2.2 If you have any questions, comments or complaints about our use of your personal data or contents of this Privacy Notice, please do not hesitate to contact us. You can email us at info@chartr.co
3.1 We collect and receive personal data using different methods:
(a) Personal data you provide to us. You may give us your personal data directly, for example, when you subscribe to receive newsletters on our Website, contact us with enquiries, complete forms on our Website or provide feedback to us.
(b) Personal data we collect automatically, including through cookies and other similar technologies. When you access and use our Website, or interact with our emails including our newsletters, we may collect personal data automatically, including through our use of cookies and other similar technologies. For more information, please see our dedicated Cookie Notice here.
(c) Personal data received from third parties. We may receive personal data from third parties. Such third parties may include analytics providers, data brokers, third party directories, recruitment agencies or related service providers, and third parties that provide technical services to us so that we can provide our Website and our Service.
4.1 We may collect the following types of personal data about you:
(a) Identity Data: name;
(b) Contact Data: such as e-mail address, telephone number and social media handle;
(c) Profile Data: such as information provided by you in your communications with us; information provided by you in our surveys, marketing and communications preferences; information derived about you from your Behavioural Data;
(d) Behavioural Data: such as data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about the referring URL (the webpage or other source that you were previously on before you reached our Website); information about your use of our Website, such as pageviews and events; information about when your current or previous sessions started; details about our Service you viewed on the Website; data observed or collected in relating to browsing activity on our Website (such as pageviews and events, including information about your views and interaction with our emails; information about the referring URL (the webpage or other source that you were previously on before you reached our Website; ad-click information in URL parameters; information about when your current or previous sessions started; advertising or other identifiers associated with you or your device (e.g. your device’s IDFA (iOS) or AAID (Android));
(e) Technical Data: such as information about your browser, network and/or device when you access our Website or interact with our emails including: IP address; browser type; operating system; MAC address; device manufacturer and model; device UDID/Android ID number; device IMEI number; and
(f) Recruitment Data: such as home address, date of birth; gender; country of residence; nationality; details of your eligibility to work (including documents and information that we may collect to verify this); your work preferences (including areas and dates where you are available for work); skills, qualifications, training and work history; any personal data which appears in your curriculum vitae or application; and any personal data that you volunteer during an interview or your interactions with us.
4.1 We process your personal data for the following purposes:
(a) to provide our Service (see Section 6 Provision of our Newsletter for more information);
(b) to provide our Website including improving the content on our Website to customise the content and/or layout of our Website page to suit your needs and protect against misuse of our Website;
(c) to deal with customer services and enquiries, carry out surveys and obtain feedback and promotional material;
(d) to carry out insight and analysis;
(e) to carry out our promotional and marketing activities;
(f) for recruitment purposes; and
(g) for business administration and legal compliance purposes.
For more information about these processing activities and our lawful basis for such processing, please see our Details of Processing Activities Section at the end of this Privacy Notice.
6.1 We collect your email address via a secure opt-in subscription service on the Website.
6.2 Your email address is stored in a database managed by Mailchimp which is an email address management and message sending service provided by The Rocket Science Group LLC.
6.3 We will use your email address to send our regular newsletters. These are primarily sent for conveying news and graphical information to you for your benefit. However, these newsletters may also contain promotional materials that we think may be of interest to you.
6.4 Our newsletters sent to you may contain code, provided by our email management service Mailchimp, that enables us to track your usage of the emails. This may include whether the email was opened, what links were clicked and your IP address. You may also be directed to third-party sites that are related to the topics discussed within the email message.
7. 1 When processing your personal data, we may need to share it with third parties as set out below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
(a) Third-party email marketing and CRM specialists. We may share personal data with partners such as Mailchimp who assist us in managing our newsletter database and sending out our newsletters and other email marketing communications as well as account-related communications.
(b) Third-party suppliers who provide applications/ functionality, data processing or IT services. We may share personal data with third parties who support us in providing our Website and help provide, run and manage our internal IT systems.
(c) Advertising partners. We share personal data with third party advertising partners, This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.
(d) Auditors, lawyers, accountants and other professional advisers. We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
(e) Law enforcement or other government and regulatory agencies and bodies. We may share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
(f) Other third parties. Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
8.1 Where necessary in order to provide our Website and our Service, we may transfer personal data to entities located in countries outside the UK and the EEA.
8.2 Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
8.3 When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
(a) Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government. This includes the EU-US Data Privacy Framework adopted pursuant to European Commission Implementing Decision of 10 July 2023 (and any equivalent frameworks adopted for the purposes of the UK GDPR (such as the UK Extension to the EU-US Data Privacy Framework adopted pursuant to The Data Protection (Adequacy) (United States of America) Regulations 2023);
(b) Standard contractual clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in the European Union and/or the UK.
9.1 We use cookies or similar tracking technology (“Cookies”) on our Website and in our emails for identification, analysis and advertising purposes.
9.2 In particular we may collect Technical and Behavioural Data through the use of such Cookies such as information about your browser, network and device, web pages you visit prior to coming to our Website and IP address to power our Website and record the following information about your use of our Website, including: number of clicks; internal links clicked; pages visited, your scrolling, searches made and timestamps.
9.3 To find out more about the cookies we and our partners use and how to set your preferences please see our Cookies Notice.
10. 1 We have appropriate security measures in place to protect against the loss, misuse or alteration of your information that we have collected from you on our Website. However, as transmission of information via the internet is not completely secure and we cannot guarantee the security of your information. Any transmission of your Information is at your own risk.
11.1 We will only keep your personal data for as long as necessary. For example, in respect of personal data that we process in connection with the supply of our Service, we may retain your personal data for up to six years from the date of supply of the Service and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
11.2 If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.
11.3 If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
This Privacy Notice only applies to personal data processed by us through your use of our Website and/or in connection with our business operations. However, from time to time, our Website and/or our email communications may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.
While our Website and Service are not intended for use by, or targeted at, minors (individuals under the age of 18), we may from time to time collect personal data of minors. Accordingly, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
We will not be able to provide you with our Service.
15.1 You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please email us at info@chartr.co
15.2 If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please email us at info@chartr.co
15.3 You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
15.4 As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.
16.1 The following provisions apply to our customers who are California residents and are intended to address the requirements of the California Consumer Privacy Act of 2018, as amended from time to time (the “CCPA”). As applicable, these Supplemental Terms also apply to residents of other States in the United States of America that provide for similar consumer privacy protections.
16.2 Your Information. Please see Section 4 of this Privacy Notice above for a description of what personal data we collect from you, and how we use that personal data.
16.3 Sharing your information. The Privacy Notice explains who we share your personal data with and why. In particular, please see the “Disclosure of Your Personal Data” section for specific examples of how we share your personal data.
16.4 Selling your information. We do not sell personal data in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal data from our website in order to provide you with tailored content and advertising, and may share your personal data with specialist suppliers, including third party media buying agencies and service providers, who assist us with the delivery of online personalised advertising campaigns. You have the right to opt out of this disclosure of your information. For example, when using Google Chrome, customers can customise their cookie settings to disable all cookies or block third party cookies, which only allows Chartr related cookies to be activated.
16.5 Our Cookie Notice provides more detailed information about the cookies we use and how you can manage them.
16.6 Your rights: Subject to exceptions and certain limitations under applicable law, you may have certain choices regarding our use and disclosure of your personal data, as described below:
(a) Access: You may request that we disclose to you (i) the categories of personal data we have collected about you, (ii) the categories of sources of that data, (iii) the business or commercial purpose for collecting or selling (if applicable) the personal data, (iv) the categories of third parties with whom we share personal data, and the categories of personal data shared; (v) the specific pieces of your personal data that we have collected, used, disclosed, or sold.
(b) Correction: You may request that we correct your personal data if it is inaccurate.
(c) Deletion: You have the right to request that we delete the personal data we have collected from you. Know that deletion requests are subject to certain limitations, for example, we may retain personal data as permitted by law, such as to maintain an active account, to process transactions and facilitate customer requests, and for certain other internal business purposes described in our Privacy Notice.
(d) Automated Decision-making: You have the right to opt-out of certain profiling activities.
(e) Opt-Out: You have the right to opt-out of targeted advertising and the sharing of personal data for that purpose, and any use of sensitive personal information (such as precise geo-location or financial information), except for the purposes it was collected and as otherwise permitted by law. Please note that where applicable we honour Global Privacy Control signals. We do not respond to Do Not Track signals. Click here to manage the activation of the cookies and make other opt-out choices. See our Cookie Notice for more information.
(f) Exercise your rights: To exercise these rights, you or your authorised agent can contact us directly at info@chartr.co. If we deny your privacy request, you may appeal the decision by contacting us at the email address provided. You must describe the basis for your appeal.
(g) Non-discrimination Statement. Chartr will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act, or similar U.S. state privacy laws, as applicable.
Retention. This Privacy Notice explains how long we keep your personal data for, please refer to “How long do we keep your personal data?”.
(h) Retention. This Privacy Notice explains how long we keep your personal data for, please refer to “How long do we keep your personal data?”.
Description: When you use our Website, we may process Technical Data and Behavioural Data to provide our Website to you. This includes keeping our Website secure and in working order, ensuring that we are showing you the correct notices and information. If you have a technical issue concerning our Website, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry. For more information, please see our Cookie Notice.
Lawful Basis: It is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Website in a secure and effective way.
We record preferences in relation to our use of cookies to comply with our legal obligations.
Description: If you click on one of the social media links on our Website or otherwise interact with our social media pages such as on Twitter, Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Website or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data.
Lawful Basis: It is in our legitimate interest to ensure that we provide the Website in an effective way and to promote our Website via social media.
Description: We collect and maintain personal data that you submit to us for the purpose of providing our Service that you have requested from us via our Website. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent. For more information see Section 6 Provision of our Newsletters.
Lawful Basis: We rely on consent to send you newsletters which you have subscribed to.
Description: When you make an enquiry, we will collect and process your Identity Data, Contact Data as well as any other personal data you volunteer that is relevant to your enquiry.
Lawful Basis: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and improve our customer services.
Description: From time to time, we will invite you to provide feedback about us, our Website and our Service in the form of online surveys. We will collect and process your Identity Data, Contact Data as well as any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve our Website and our Service, to assist with the selection of future product and service lines and to train our personnel.
Lawful Basis: It is in our legitimate interest to use the personal data provided by you so that we can improve our Website and our Service and provide them in an effective way.
Description: We and our third-party partners use cookies to collect Behavioural Data and Technical Data and certain Profile Data from the devices that you use to access our Website, our Service and any emails that you receive from us. Please see our Cookie Notice for further information, including details of our third-party partners.
In particular we and our third-party partners use this data to analyse how you use our Website and our Service and the effectiveness of our Website and our Service, including: a) for social media retargeting; b) to provide you with a personalised experience when you use our Website; c) to analyse how you use, and the effectiveness of, our Websites and our Service; d) to count users who have visited our Website or opened our newsletter and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Website, our Service and the effectiveness of our newsletters; e) to measure the effectiveness of our content; and f) to learn what parts of our Website and Service are most attractive to our users, which parts of our Website and Service are the most interesting and what kind of content, features and functionalities our visitors like to see; and g) to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and h) to help us with website design and to remember your preferences.
Lawful Basis: Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Website and Service, it is in our legitimate interest to use your personal data in such a way to improve our Website and our Service.
Description: We may from time to time use your Contact Data to send our marketing communications to you by email. You may indicate your preference to opt out of receiving promotional or email communications by following the unsubscribe instructions provided in every email you receive or by contacting us directly at info@chartr.co
Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.
Where we are sending you personalised marketing, we may also use Behavioural Data to help us decide what sort of personalised marketing to send you.
Lawful Basis: It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.
However, we will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email to certain business users of our Service.
Description: We and our third party partners may use your Behavioural Data and Technical Data and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms).
By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Site or which you otherwise might be interested in based on your browsing habits, although our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties.
Lawful Basis: Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Service to you.
Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider, as set out in our Cookie Notice.
Description: If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Products and Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
Lawful Basis: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Service to others, in an effective way.
Description: We use your Identity Data, Contact Data and Recruitment Data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data, Contact Data and Recruitment Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from other third parties we work with in relation to our recruitment activities, including without limitation, background check providers, credit reference agencies and your referees.
We also use your Recruitment Data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation.
Lawful Basis: Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Activity: Complying with our legal obligations or in connection with the administration of our business
Description: We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Lawful Basis: Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
Last updated November 10, 2023.
