This Privacy Policy outlines Ventham Consulting's ("we", "our", or "the Consultancy") practices with respect to information collected from users who access our website at https://www.venthamconsulting.co.uk ("the Site") or otherwise share personal information with us (collectively: "Users").
"Ventham Consulting" is the trading name of Ventham Consulting Limited, company number 15241384, registered in England & Wales, at Unit 1, EMP Building, 4 Solent Road, Havant, Hampshire PO9 1JH.
In providing services to clients, Ventham Consulting acts as (a) data processor on behalf of the client, or (b) as a separate data controller – depending on the degree of control Ventham Consulting has over the purpose(s) and means of the data processing. Where we act as a data processor, the relevant data controller is the client. The conditions under which Ventham Consulting is a data controller are generally limited to such data provided by clients and which is processed for the purposes of “Know Your Client” (“KYC”) due diligence, in the course of preparation of contracts, etc.
Within the context in which Ventham Consulting is deemed to be a data controller under Data Privacy Laws, this notice fulfills our obligation to provide certain information to third parties whose personal data we process in this capacity (as required by Article 14 of the GDPR), and the notice requirements set out in other relevant data privacy laws for processing personal data which has been obtained indirectly.
The responsible authority within the meaning of data protection laws, in particular the General Data Protection Regulations (GDPR), is held under the laws of England and Wales.
User Rights
You may request to:
(a) receive confirmation as to whether or not personal information
concerning you is being processed, and access your stored personal
information, together with supplementary information;
(b) receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format;
(c) request rectification of your personal information that is in our control;
(d) request erasure of your personal information;
(e) object to the processing of personal information by us;
(f) request to restrict processing of your personal information by us; or
(g) lodge a complaint with a supervisory authority - within the United Kingdom, the Information Commissioner's Office (ICO).
However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the above rights or receive more information, please contact us through the Contact Form.
Retention
We will retain your personal information only for as long as is necessary to provide our services, and to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods are determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated or unused information at the earliest practicable opportunity. We retain records containing client personal data, contractural documents, communications, and any other material as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Grounds for data collection
Processing of your personal information (i.e. any information which may potentially allow your identification through reasonable means; hereinafter "Personal Information") is necessary for:
(a) the performance of our contractual obligations towards you and providing you with our services;
(b) to protect our legitimate interests; and
(c) for compliance with legal and financial
regulatory obligations to which we are subject.
Ventham Consulting will use its best endeavours and appropriate security procedures (both electronic and physical) to protect the confidentiality of its clients and their information.
When you use the Site or otherwise contact and engage with us, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.
Users are encouraged to read carefully this Privacy Policy and use it to make informed decisions.
What information do we collect?
We collect two types of data and information from Users.
The first is non-identifiable information pertaining to a User, which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from whom Non-personal Information is collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is Personal Information , which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
- Device Information. We may collect Personal Information from your device, which includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
- Registration information. When you send a message through our Site you will be asked to provide your name, email address and telephone number.
How do we receive information about you?
We may receive your Personal Information from various sources:
- when you voluntarily provide us with your personal details through contacting us;
- when you use or access our Site in connection with your use of our
services; or
- from third-party providers, services and public registers (for example, traffic analytics vendors).
How is the information used? With whom do we share the information?
Ventham Consulting maintains the confidentiality and privacy of its clients and prospective clients. We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.
We may use the information for the following purposes:
(a) to communicate with you; and
(b)
to establish bona fides of all potential clients.
We may also transfer or disclose Personal Information to affiliated companies and subcontractors.
In addition to the purposes listed in this Privacy Policy, Personal Information may be shared with trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes:
- hosting and operating our Site;
- providing you with our services, including providing a personalised display of our Site;
- storing and processing such information on our behalf;
- performing research, technical diagnostics or analytics.
We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary in order to:
(a) comply with any applicable law, regulation, legal process or governmental request;
(b) enforce our policies (including any Contractual Agreement), including investigations of potential violations thereof;
(c) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
(d) establish or exercise our rights to defend against legal claims;
(e) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
(f) for the purpose of collaborating with law enforcement agencies and/or if necessary in order to enforce intellectual property or other legal rights.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information a website assigns to your device while you are viewing a website. Cookies are helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, making the interaction between you and our Services quicker and easier, and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
(a) 'session cookies', which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;
(b) 'persistent cookies', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
(c) 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We use a tool which is based on Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.
Use of script libraries (Google Web Fonts)
In order to present our content correctly and make it graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts (https://fonts.google.com) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font.
- Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible for – but currently also unclear whether and, if so, for what purposes – operators of corresponding libraries collect data.
- The privacy policy of the library operator Google can be found at https://policies.google.com/privacy.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party to whom you choose to disclose information.
This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set out in this Privacy Policy.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the
Site and your information. We employ industry standard procedures and policies
to ensure the safety of the information we collect and retain, and to prevent
unauthorised use of any such information, and we require any third party to
comply with similar security requirements, in accordance with this Privacy
Policy. Although we take reasonable steps to safeguard information, we cannot
be responsible for the acts of those who gain unauthorised access or abuse our
Site, and we make no warranty, express, implied or otherwise, that we will
prevent such access.
Transfer of data outside the EEA
Although the United Kingdom now lies outside the European Economic Area (EEA) it remains compliant with data policies consistent with it. Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries approved as providing an adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Advertisements
Ventham Consulting does not initiate or distribute advertising.
Third-party advertising technology - over which we have no control - may be used to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party advertising networks operated by NAI and DAA members, please visit their respective websites:
https://optout.networkadvertising.org
Marketing
Ventham Consulting does not use your Personal Information (such as your name, email address, telephone number) for the purpose of providing you with promotional materials concerning our services.
Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Minors
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children, and no contractural engagement will be made, or is implied to be sought, with anyone not an adult. Under no circumstances shall we engage with, or offer our services to, minors. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us through the Contact Form.
Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us through the Contact Form.
How to contact us
Electronically through the Contact Form on the Site.By postal delivery to Ventham Consulting Limited, registered at Unit 1, EMP Building, 4 Solent Road, Havant, Hampshire PO9 1JH, United Kingdom.
Last Modified 2nd January 2024