Last Revised: 20 February 2024
Infuse is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures.
- providing services to you or our clients;
- you use our Website (infuse.it); or
- performing any other activities that form part of the operation of our business.
The policy also explains what we use the information for, who we share it with, and also sets out your rights and whom you can contact for more information.
Information about you that we process
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation (UK GDPR and DPA 2018) and as set out in this statement.
We may process information about you that: (i) you provide to us, (ii) that we obtain from third parties or (iii) that is publicly available. This information may include your name, age, gender, date of birth and contact details. It may also include ‘sensitive’ or ‘special categories’ of personal data, such as dietary requirements or mobility information.
How we use information about you
Some of your personal data may be used for other business purposes, such as:
• legal or regulatory requirements;
• requests and communications from competent authorities;
• financial accounting, invoicing and risk analysis;
• relationship management, which may involve:
- sending you thought leadership or details of our products and services;
- contacting you for feedback on services;
- sending you event invitations; and
- other marketing or research purposes;
• recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
• services we receive from our professional advisors, such as lawyers, accountants and consultants;
• investigating or preventing security incidents; or
• protecting our rights and those of our clients.
In addition to the above, we may also use your personal data collected via our Website:
• to manage and improve our Website;
• to tailor the content of our Website to give you a more personalised experience;
• to draw your attention to information about our products and services that may be of interest to you; or
• to manage and respond to any request you submit through our Website.
Legal grounds for processing personal data
• you have explicitly agreed to us processing your information for a specific reason;
• the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
• the processing is necessary for compliance with a legal obligation such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
• the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
- to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- to prevent fraud;
- to protect our business interests;
- to ensure that complaints are investigated;
- to evaluate, develop or improve our services or products; or
- to keep you or our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
• you have given us your explicit consent to process that data;
• the processing is necessary to carry out our obligations under employment, social security or social protection law;
• the processing is necessary for the establishment, exercise or defence of legal claims; or
• you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Sharing your personal data
In connection with any of the purposes outlined above, we may disclose details about you to:
• third parties that provide services or online platforms to us;
• competent authorities (including courts and authorities regulating us);
• your employer and/or its advisers, or your advisers;
• any other person or organisation after a restructure, sale or acquisition of Infuse, as long as they use your information for the same purposes we did;
• credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
• other third parties that reasonably require access to personal data relating to you.
Protecting your personal data
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data to a ‘need to know’ basis; and
• technological security measures, including fire walls, encryption and anti-virus software.
The transmission of data over the internet (including by e-mail) is never completely secure, so although we use appropriate measures, we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal data for
We seek to ensure that we only keep your personal data for the longest of:
• the period necessary for the relevant activity or services;
• any retention period that is required by law; or
• the period in which litigation or investigations might arise in respect of the services.
You have various rights in relation to your personal data. In particular, you have a right to:
• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed);
• ask that we update and/or correct the personal data we hold about you;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
• ask us to stop or start sending you marketing messages at any time; and
• object to our processing of your personal data.
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
Third party sites
Right to complain
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
• writing to Data Protection Officer, Infuse Consulting Ltd at Watergates Building, 109 Coleman Road, Leicester, LE5 4LE.
• sending an email to email@example.com
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.