Welcome to TUSSELL LIMITED’s privacy notice. We respect your privacy and are committed to protecting your personal data.
We (“Tussell” and/or “us” or “we”) are a data company who collect and provide information on public sector commercial contracts (known as “Tussell Insight”) to our customers and other users. We are a company registered in England and Wales with company number 09454393 whose registered office is at 25 Moorgate, London EC2R 6AY.
This privacy notice aims to give you information on how we collect and processes personal data through your use of this website and through Tussell Insight. We are the data controller in respect of this personal data that we collect. This privacy notice will then inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager at firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, last name, username or similar identifier, title and email address.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Third parties or publicly available sources. We receive personal data about you from various third parties and public sources including through government and EU websites, Companies House and other providers. Tussell Insight contains public sector information (a) licensed for use by the UK Government under the Open Government Licence v3.0 and/or (b) from the EU Tenders Electronic Daily website licenced for re-use by the European Commission.
4. LEGAL BASIS FOR PROCESSING
The legal basis for which we process personal data obtained for inclusion in Tussell Insight is Article 6(1)(f) GDPR – Legitimate Interests.
The processing of limited personal data is necessary for the effective use of Tussell Insight as it enables users to identify potential customers and suppliers of government services. It is also the basis upon which we may collect certain limited data on you for marketing purposes.
All Tussell personal data is of a limited nature, relates to individuals in a professional capacity and is usually publicly available either under the Companies Act 2006 or by virtue of having been made public by the public organisation in which the individuals are involved (usually via the company’s website). Consequently, the proposed use of the personal data is related to the individuals’ role within their entity and is likely to elicit relevant contact within the reasonable expectations of those individuals i.e. from professional organisations offering services, funding opportunities and business connections to the entity that the data subject represents.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We disclose personal data held in Tussell Insight and other personal data we hold to the following categories of recipients:
•To our clients, who use Tussell Insight personal data in accordance with their selected usage in their business including for limited business-to-business direct marketing purposes subject to carrying out such marketing in accordance with applicable data protection and privacy laws;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• third party service providers (as permitted by Tussell in writing from time to time): Accountants, auditors, lawyers and other outside professional advisors; IT systems, support and hosting service providers; document and records management providers; and similar third-party vendors and outsourced service providers assisting us in carrying out business activities;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business for the purposes of their internal due diligence;
• to any other person with your consent to the disclosure.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. INTERNATIONAL TRANSFERS
Some of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• Pease Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers for six years after they cease being customers. In some circumstances you can ask us to delete your data and please see section 9 below for more information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
TYPES OF COOKIES
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.]
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name & Purpose
• This cookie is set when you give visitors the choice to opt out of cookies.
For more information on the Cookies used by our CRM HubSpot, please consult their Cookies page.
• This cookie is used to determine and save whether the chat widget is open for future visits.
• It is set in your visitor's browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity.
• If your visitor manually closes the chat widget, it will prevent the widget from re-opening on subsequent page loads in that browser session for 30 minutes.
• It contains a boolean value of True if present.
• It expires in 30 minutes.
• This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed.
• It contains a boolean value of True or False.
• It expires in one day.
• This cookie is set when visitors log in to a HubSpot-hosted site.
• It contains encrypted data that identifies the membership user when they are currently logged in.
• It expires in one year.
• It contains the string "yes" or "no".
THIRD PARTY COOKIES
Reflect Digital (Reflect Digital are a digital marketing agency who utilise advertising software - including Google Analytics, StackAdapt Pixel, Twitter Pixel and PageSense - to monitor advertising-related traffic for Tussell)
To deactivate the use of third party advertising cookies, you may visit the consumer page to manage the use of these types of cookies.
In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed.
The links below provide instructions on how to control cookies in all mainstream browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
Safari (iOS): https://support.apple.com/en-gb/HT201265
Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)