Capella Synergy (“The Company”) is strongly committed to protecting personal data. This privacy notice describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. The Company processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When you make an enquiry with us about any of the services we offer, we’ll ask you to provide some contact information. This may include some or all of the following:
- full name
- landline and mobile phone number
- email address
How do we use your personal information?
We will use your personal information to enable us to contact you to enable us to provide our services to you.
The law requires us to comply with a number of regulations. Where necessary, we use your personal data to allow us to fulfil our legal and regulatory requirements.
We will only share personal information with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Sometimes we may pass your information on to third parties who provide services to us. When we do this it is on the understanding that they care for your information as carefully as we do, keep it confidential and use it only for the agreed purposes above.
Throughout your relationship with us, we will hold your personal information securely in our systems. This will include any information provided by you or others in various ways, including (but not limited to) in applications, emails and letters, during telephone calls and conversations in our offices, when registering for services, and when using our website.
Under Data Protection regulations individuals have a number of rights. These are as follows:
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data.
We do this in our GDPR Policy.
Right of access
Individuals have the right to access their personal data and supplementary information. Individuals have the right to obtain:
- confirmation that their data is being processed
- access to their personal data
- other supplementary information
We will not charge for initial requests to provide information, but may charge a fee if requests for further copies of the same information are made. We will provide the requested information to you within a month of receiving your request, unless the request is complex or numerous in which case we may extend this period by up to a further two months.
Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to provide the information requested or refuse to respond. In these instances, we will inform you and explain our reason.
Before we proceed with any request, we will take steps to verify the identity of the person making the request.
Right to rectification
Individuals have the right to request that inaccurate personal data is rectified or completed if it is incomplete. If you make such a request, we will take steps to verify whether the data is accurate. Where we accept that the information is inaccurate, we will take steps to rectify it. If we believe that the information is accurate and does not require rectification we will notify you and explain our reason.
Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to rectify the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.
Right to erasure (known as the “Right to be forgotten”)
Individuals have the right to have their personal data erased if:
- the personal data is no longer necessary for the purpose which it was originally collected
- we rely upon consent as our lawful basis for holding the data and you withdraw that consent
- we have processed your personal data unlawfully
- we have to do it to comply with a legal obligation
The right to erasure does not apply where processing is necessary for one of the following reasons:
- to exercise the right of freedom of expression and information
- to comply with a legal obligation
- for the performance of a task carried out in the public interest or in the exercise of official authority
- for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing
- for the establishment, exercise or defence of legal claims
Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to remove the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.
Right to restrict processing
Individuals have the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data in the following circumstances:
- you contest the accuracy of your personal data and we are verifying its accuracy
- the data has been unlawfully processed and you oppose erasure, requesting restrictions instead
- we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim
- you have objected to us processing your data and we are considering whether our legitimate grounds override your request
If you choose to exercise this right, we may not be able to proceed with a transaction or provide you with our advice. This may mean that we are unable to submit or progress a transaction with a product provider. In these instances we will notify you of the impact of your request.
Right to data portability
The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. The right to data portability only applies:
- to personal data you have provided to us
- where the processing is based on your consent or for the performance of a contract
- where processing is carried out by automated means
- When responding to such a request, we would provide the personal data in a structured, commonly used and machine-readable form, typically a .CSV file. We will provide this to you within one month of receiving your request. If your request is complex or requires more time, we may extend this period by up to a further two months. We will contact you and inform you why it will take longer.
Right to object
Individuals have the right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- direct marketing (including profiling)
- processing for purposes of scientific/historical research and statistics.
If you exercise your right to object, we will stop processing your personal data unless:
- there are compelling legitimate grounds for us to continue to process, which override your interests, rights and freedoms
- the processing is for the establishment, exercise or defence of legal claims
You can exercise your right to object at the first point of contact with us or at any other time by contacting us a detailed below. If exercising your right to object affects or prevent us from being able to provide you with one or any of the services we offer we will inform you.
To exercise any of your rights detailed above you can contact us as detailed below:
We take the privacy of your personal information very seriously. If you ever feel you need to complain about how we’ve handled your personal information and data you can contact us as below.
Contact Suzi Johnson via email on firstname.lastname@example.org or by telephone on +44 (0) 77175 10876.
If you’re still unhappy with any aspect of how we handle your personal information, you also have the right to contact the Information Commissioner’s Office (ICO). The ICO is the UK’s independent body set up to uphold information rights. You can contact it as follows:
Via its website: https://ico.org.uk
Or in writing to
Information Commissioner’s Office
Call: 0303 123 1113
Changes to this privacy notice
We reserve the right to alter this privacy notice at any time. Such alterations will be posted on our website. You can also obtain an up-to-date copy of our privacy notice by contacting us as above.
Should you object to any alteration, please contact us.