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PRIVACY & COOKIES POLICY

Pearlfinders Privacy & Cookies Policy

1.       Introduction

This Privacy & Cookies policy explains the Privacy & Cookies policy of
Pearlfinders Limited (“Pearlfinders”), Company No. 04473277 Vat No. 798 5814 56,
whose registered address is Pearlfinders Limited, Albert House, 256-260 Old
Street London EC1V 9DD

Pearlfinders’ primary line of business is to provide research, information and
data to sales and marketing professionals. These services (“Services”) are
provided to an ever-changing group of clients – primarily marketing agencies,
sports teams, arts & cultural institutions, charities, technology consultancies
and HR service providers.

Pearlfinders is committed to protecting and respecting your privacy. Where we
decide the purpose or means for which personal data supplied by you or us is
processed, we are the "data controller".

Specifically, Pearlfinders is committed to ensuring that all data processing is:
-

 * processed lawfully, fairly and in a transparent manner;

 * collected for specified, explicit and legitimate purposes;

 * adequate, relevant and limited to what is necessary in relation to the
   purposes for which they are processed;

 * accurate and, where necessary, kept up to date;

 * kept in a form which permits identification of data subjects for no longer
   than is necessary; and

 * processed in a manner that ensures appropriate security of the personal data.

The purpose of this document is to explain how Pearlfinders will use your
personal information when interacting with us.

We have deliberately attempted to write this privacy policy in clear,
easy-to-understand language. If anything about it isn’t clear, please call us on
+44 (0)203 871 2852 or email us at subs@pearlfinders.com and we will get back to
you with clarification.

We may choose to make changes to this Privacy Policy at any time, to ensure
compliance with applicable laws and industry regulations. Please ensure that you
review this document from time-to-time to ensure you are familiar with the
latest changes. These changes are effective immediately, after they are posted
on this page.

2.       Collection of personal information

Why do we collect personal information about you?

The reason we chose to collect and process personal information depends on your
relationship with Pearlfinders: -

Brand: If you are a marketing, HR or technology decision-maker at a brand (for
example a Marketing Director at a bank, or Head of IT at a retail business), we
may collect and process personal data on you, and subsequently feature this
information on our web platform Pearlfinders.com. The objective of Pearlfinders
is to help our clients connect and ultimately build relationships with
businesses they are interested in working with in a more effective manner.

Client: If you are a client of Pearlfinders, we collect and process personal
information in order to most effectively deliver the service that you have
subscribed to.

Prospect: If you are a Prospect (a business that we believe is likely to benefit
from subscribing to Pearlfinders’ services), we may collect and process personal
data on you as part of our efforts to sell, promote and market our services to
you.

Supplier: If you are a supplier to Pearlfinders, we collect and process personal
information as part of our contractual relationship with you.

 

How do we collect personal information from you?

Information may be collected in the following ways: -

 * Directly (e.g. in a face-to-face meeting, phone call or videoconference)

 * Email (e.g. in a negotiation with one of our sales team)

 * Desk research (in this case, only publicly-available personal information is
   processed –e.g. we may find and store information that you have posted on
   LinkedIn)

 * Post (e.g. we may record data that you send to us by post)

 

What type of information is collected?

The types of data we will collect may include: -

 * Contact Data: your name, corporate email address, workplace address.

 * Research Data: publicly-available information such as that which you have
   posted on LinkedIn or which is available on a corporate website; reports
   written by our research team, detailing your business challenges; job
   history.

 * Correspondence Data: records of emails that we have sent you/you have sent
   us.

 * Subscription Data: details of a subscription you have taken out with us,
   including username, passwords, account information.

 * Financial Data: your payment information and transactions, including your
   payment for subscriptions with us.

 * Analytics Data: your IP address or other device identifier, technical log
   information (as described below under the subheading “Log Data”) cookies (as
   described below under the subheading “Cookies”), and information about how
   you use our website.

All data collected and processed by Pearlfinders is ‘corporate’ or ‘business to
business’ data.

Pearlfinders has trained its staff to ensure that no ‘special categories’ or
personal data (e.g. the ethnicity, or religious beliefs of data subjects) are
collected and/or processed.

Pearlfinders does not collect or process personal data on children.

Grounds of processing

The table below explains the ways in which we use your personal data and the
legal grounds for that processing.  Please contact us at subs@pearlfinders.com
if you would like further information about the relevant legal grounds.



Legitimate interest

Pearlfinders processes your personal information when it is in our legitimate
interest to do so and when these interests are not overridden by your data
protection rights. 

Prior to using Legitimate Interest, we have undertaken a Legitimate Interests
Assessment and a Data Protection Impact Assessment.

The Legitimate Interest is our interest in providing our services to our
customers in pursuit of our customers legitimate interest in getting to know you
better to understand when and how they should be contacting you and what they
should be offering, so they can offer products and services which are better
suited to your requirements. 

So, by processing your personal data, you are more likely to receive
communications from our clients about products and services that are relevant to
your role, and we have taken steps to ensure the processing is very unlikely to
have an adverse impact on your privacy.

We are careful not to process any sensitive or special categories of personal
information, and restrict data processing to corporate (B2B) data. 

How is your information used?

We use your information for a variety of reasons, depending on the nature of
your relationship with us, including: -

 * to deliver the service that you have signed up to effectively;

 * including your personal data on Pearlfinders.com, and making it available to
   our clients;

 * to make a decision on whether or not to try and sell our services to you; and

 * to deliver a tailored programme of account management.

Disclosure to third parties

For brand data, we may choose to disclose your personal information to a select
group of third parties, namely subscribers to the Pearlfinders.com platform. We
do this because we believe that by doing so, you are more likely to receive
relevant business introductions that will be of interest to you in a corporate
capacity. On the flipside, you are less likely to receive irrelevant
introductions, sent in the wrong way at the wrong time.

We are committed to real transparency about this element of our data processing,
so may speak to you about it on the phone or send you an email
explaining/confirming that we are processing your personal data and it will be
shared with third parties.

We are committed to giving you the opportunity to ask for us not to disclose
your information to these third parties. If you object, please tell us on the
phone, reply to an email we’ve sent you, email subs@pearlfinders.com or write to
us at the address above.

3.       Your rights

You have the following rights over the way we process personal data relating to
you. We aim to comply without undue delay, and within one month at the latest.

 Controlling personal information that we hold on you

As a data subject, we acknowledge that you have a right to control whether or
not we collect and process personal data on you, and to ask for us to stop
processing/delete data that we hold.

Pearlfinders is committed to ensuring that we process personal data in line with
your wishes, so please tell us if you’re unhappy with us holding any of the data
that we do. You can do this: -

 * By phone: please call +44 (0)203 871 2852

 * Write to us: Pearlfinders Ltd, Albert House, 256-260 Old Street, London EC1V
   9DD

 * By email: Please email subs@pearlfinders.com

We will ensure that any requests for personal data to be deleted, are actioned
within 2 business days of the request being received.

Keeping the data we hold on you up to date

We endeavour to keep the information that we hold on you as up-to-date as
possible, so have put in place a process to clean our data on a rolling cycle,
with the help of third party specialist software providers and suppliers. If you
find that any data on Pearlfinders.com is not up-to-date or, you receive a
communication from us that includes incorrect information, please alert us by
emailing subs@pearlfinders.com.

Ask for a copy of data we are processing about you and have inaccuracies
corrected

You have the right to request a copy of the personal information we hold about
you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply personal
information held about you on our files (and with any third parties to whom it
has been disclosed to).If we are processing data in order to perform our
obligations to you, or because you consented, if that processing is carried out
by automated means, we will help you to move, copy or transfer your personal
data to other IT systems.

4.       Cookies

Cookies are files that include very small amounts of data, commonly used as an
anonymous unique identifier. These are transmitted to your web browser from the
web page that you have visited, and may subsequently be stored on the hard drive
of the computer (or other device) that you are using.

If you are a client of Pearlfinders, when you first access our Services, you
will notice a pop-up message informing you about our collection of Cookies and
usage of them to improve our Services. This message will allow you to either
accept or refuse. If you select the latter, you may find it difficult to
optimally use some portions of our Service.

Most web browsers allow some control of most cookies through the browser
settings. To find out more about cookies, including how to see what cookies have
been set and how to manage and delete them, visit http://www.aboutcookies.org or
http://www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit
http://tools.google.com/dlpage/gaoptout.

5.       Email marketing & newsletters

From time-to-time we may send you content via email that we believe is likely to
be of interest to you.

For companies that we believe are likely to be interested in our services
(marketing/PR agencies; martech providers; sports teams; other rights holders
within sport; arts and cultural institutions; charities, HR consultancies;
technology businesses) we may from time to time decide to send you information
by email, post or phone that we believe will be of interest to your role.

This information may include extracts of research that we have done, or the
opportunity to speak with our team to conduct a demonstration of the
Pearlfinders platform. If you’re not interested in receiving these
communications, please let us know.

For both this activity, we use an email distribution engine called Pardot (owned
by Salesforce). Please consult Pardot’s Privacy Policy for more information:
https://www.salesforce.com/company/privacy/

For Pearlfinders clients, we will also send regular emails – to update you on
latest information available via our service.

For this activity, we use an email software programme called MaxEmail, owned by
xtremepush. Please consult xtremepush’s Privacy Policy for more information:
https://maxemail.xtremepush.com/cookies-and-privacy-policy/We are careful to
ensure that all email correspondence sent out by Pearlfinders includes a clear
‘unsubscribe’ link, and have a robust internal policy in place to deal with
unsubscribe requests we may receive from stakeholders.

6.       Data Security

All data held by Pearlfinders on its clients and their associated business
activities, by staff at our office, and working remotely, is located within an
ISO 27001 certified Data Centre. This independently recognised standard for data
security and management provides a high level of security for Pearlfinders and
its clients, in particular in relation to the confidentiality, integrity and
availability of data across the network.

The organisation uses software countermeasures and management procedures to
protect itself against the treat of malicious software. All staff are trained to
co-operate with this policy. 

The Pearlfinders.com website is hosted in a secure data centre, which meets both
ISO 27001 and ISO 27002 standards, as well as being in possession of an in-depth
Business Continuity (BC) plan. While the data centre is also PCI-DSS compliant,
this is currently irrelevant due to the website not processing e-commerce
payments.

Any third party applications Pearlfinders may choose to make available to its
clients will not provide Pearlfinders or any other party with access to
confidential client data.

While we take reasonable steps to maintain secure internet connections, if you
provide us with personal information over the internet, the provision of that
information is at your own risk.

7.       Log Data

For those clients and former-clients who have previously logged into
Pearlfinders, or clicked on a link in one of our email newsletter
communications, we are keen to inform you that we may collect information that
your browser sends (referred to above as Log Data). This may include information
such as your device’s IP Address, browser type and version, pages of the Service
that you access, the time and data that such activity takes place, time spent on
each pages, the entry and exit points of your browsing session, and other data.

We work with a number of recognised third party providers – including Google,
MaxEmail (provided by xtremepush) and Salesforce.com – to ensure that this data
is collected and stored in a secure manner.

Privacy policies of these organisations can be found here: -

 * Google: https://policies.google.com/privacy?hl=en-GB&gl=uk

 * Emailcenter: https://maxemail.xtremepush.com/cookies-and-privacy-policy/

 * Salesforce.com: https://www.salesforce.com/company/privacy/

The reason for such activity – which will be reviewed from time to time – is to
improve your experience of the Services.

8.       Retention of data

Pearlfinders may retain data for differing periods of time for different
purposes as required by law or best practices. However, under no circumstances
will we retain your personal data for a period of longer than five years (from
the point of collection, or updating) unless there is a critical business reason
to do so (for example, we may need to maintain records of invoices issued to you
for longer than this for accounting reasons).

We would be happy to provide a copy of our data retention policy if you’re
interested in receiving more information on this point.

9.       Public website

All elements of Pearlfinders.com that aren’t behind the paywall (the ‘Public
Site’) are hosted on a web content management system called Squarespace.

We may from time to time collect anonymous data on usage patterns on the public
website. Please view Squarespace’s Privacy Policy here:
https://www.squarespace.com/privacy/

10.   Links to Other Sites

Our Service may contain links to other sites. If you click on a third-party
link, you will be directed to that site. Note that these external sites are not
operated by us. Therefore, we strongly advise you to review the Privacy Policy
of these websites. We have no control over, and assume no responsibility for the
content, privacy policies, or practices of any such third-party sites or
services.

11.   If you email us

We work closely with a third party IT support business (London Systems) to
encrypt and protect email traffic in line with government advice. If your email
service does not support TLS, please be aware that any emails we may
send/receive may not be fully protected after we have sent them to you.

We will also monitor any emails sent to us, including file attachments, for
viruses or malicious software. Please be aware you have a responsibility to
ensure that any email you send is within the bounds of the law.

12.   The personal information of children

Our Services do not address anyone under the age of 13. We do not knowingly
collect personal identifiable information from children under 13. In the case we
discover that a child under 13 has provided us with personal information, we
immediately delete this from our servers. If you are a parent or guardian and
you are aware that your child has provided us with personal information, please
contact us so that we will take the necessary action.

13.     International Data Transfers

Your Personal Information which you supply to us is generally stored and kept
inside the European Economic Area (EEA), however due to the nature of our global
business and the technologies required, your Personal Information may be
transferred to third party service providers outside the EEA, in countries where
there may be a lower legal level of data protection.

Where we transfer your data outside of the EEA, we transfer the minimum amount
of data necessary, anonymise it where possible and we have agreements in place
with those parties which include standard data protection clauses to ensure that
appropriate safeguards are in place to protect your personal data in accordance
with this Privacy Policy and European levels of data protection. 

14.     Complaints

If you are unhappy with the way we are processing your personal data, please let
us know.

If you do not agree with the way we have processed your data or responded to
your concerns, or if you do not think we are handling your personal information
adequately, you have the right to lodge a complaint with the Information
Commissioner's Office. Further information, including contact details, are
available at https://ico.org.uk

14.   Contact us

If you have any questions or suggestions about our Privacy Policy, please do not
hesitate to contact us (emails can be submitted to subs@pearlfinders.com, or you
can telephone us on +44 (0)203 871 2852).

Contact

 +44 (0) 203 871 2852

subs@pearlfinders.com

256-260 Old Street, London England, EC1V 9DD, UK,

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