This privacy policy applies to the processing activities of Cumulus9 (as defined below). As part of our day-to-day business we need to collect personal information from our customers and potential customers to ensure that we can meet their needs and provide them with information about our services. Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals.
This policy outlines how we manage your personal information supplied to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or website(s). It also details your rights in respect of our processing of your personal information. Our privacy policy will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
Any personal information we hold will be governed by our most current privacy notice.
Cumulus9 Limited (“Cumulus9”) provides quality assurance testing services in respect of regulatory reporting, including but not limited to reference data testing, accuracy testing and regulatory reconciliations to international clients and is the data controller of your personal information in relation to those services.
Please note that if you are a Cumulus9 employee, your personal information will be used in connection with your employment contract. Any reference to ‘us’, ‘our’, ‘we’ or ‘Cumulus9’ in this privacy notice is a reference to Cumulus9. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to any of our customers and potential customers as the context requires unless otherwise stated.
If you are an actual or potential customer, we may collect the following types of information about you:
We obtain this information in a number of ways through your use of our services or other dealings with us including through the Cumulus9 website, the customer on-boarding process, marketing sign up forms, subscribing to blogs and from information provided in the course of ongoing customer service correspondence. We may also obtain personal information about you through your use of our website or through the use of cookies on our website and, in particular by recording which pages you look at on our website.
We may ask for other personal information voluntarily from time to time (for example, through market research or surveys). We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice. Further, if you visit our offices or premises, we may have CCTV which will record your image.
As part of using your personal information for the purposes set out above, we may disclose your information to:
Generally, we require that third party organisations who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the all relevant data protection laws and this privacy notice.
Where our use of your personal information requires your consent, such consent will be provided in accordance with the applicable terms and conditions of use on our website or any other contract we may have entered into with you or as set out in our communication with you from time to time. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this privacy notice.
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary.
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time.
If we hold any personal information in the form of a deed, we will hold this deed in its complete form for a period of 12 years after our business relationship with you has ended. If we hold any personal information in the form of a recorded communication, by telephone, electronic, in person or otherwise, this information will be held in line with local regulatory requirements which will either be 5 years or 10 years after our business relationship with you has ended. Where you have opted out of receiving marketing communications we may hold your details on our suppression list so that we know you do not want to receive these communications but we will not send you marketing communications.
We may use personal information for the following purposes:
As part of providing services or information about our services to you, we will need to verify your identify to set you up as a customer and we will need to use those details in order to effectively manage your account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity or checks on our behalf.
Once you become a customer, or subscribe to our website or blogs, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the most appropriate products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.
We may from time to time use personal information provided by you through your use of the services and/or through customer surveys to help us improve our products and services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can and to continue to be a market leader in our industry.
We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible
We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so as it is in our legitimate interest or with your consent.
We may need to process your personal information for internal business and record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
If we undergo a corporate restructure or part or all of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition. Such use may involve disclosing your details as part of a due diligence exercise. It is our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
If you enter any of our premises we may record your image on our CCTV for security reasons. We may also take your details to keep a record of who has entered our premises on any given day. It is in our legitimate interest to do this to maintain a safe and secure working environment.
The information about any rights that might be available to you in relation to the personal information we hold about you is set out below.
Rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Erasure
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations and subject to section ‘How do we store personal information and for how long’.
Processing restrictions
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Data Portability
Under the General Data Protection Regulation (679/2016), you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
Objection
You can ask us to stop processing your personal information, and we will do so, except if we can demonstrate compelling legal grounds for the processing.
A cookie is a small piece of text stored on your computer or device when you visit a website. We use cookies on our website to provide you with a more relevant and effective experience, including presenting web pages according to your needs or preferences. For further information about cookies and how we use cookies, please refer to our website.
We are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy notice at the time of the change.
Our website or our apps may have links to external third party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set below. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the site. You are advised to review this Privacy Policy periodically for any changes.
If you have any questions about this Privacy Policy, please feel free to contact us.
Registered Office:
Cumulus9 Limited
30 St. Mary Axe
London EC3A 8BF
United Kingdom
Cumulus9 Limited is a company registered in England and Wales with company number 13607450.