Privacy Policy
Date last revised: 1 December 2023
3N STRATEGY LIMITED (we/us/our) is committed to protecting your personal data. We recognise that this data is your property and that you have loaned it to us for specific purposes. Unless otherwise required by applicable data protection laws, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you, or the way you ask us to, and we will give it back to you at any time.
1. THIS POLICY
1.1 This is our privacy policy. It sets out how we process your personal data when:
1.1.1 we engage with you in correspondence as part of our working relationship with you;
1.1.2 you visit our websites, located at www.3nstrategy.com (Website), www.hranalyticsthinktank.com (ThinkTank)
and our sub-domains; and/or
1.1.3 you participate in activities run or managed by us;
1.2 This policy applies to our contract(s) with you whether you have signed a contract directly or are engaging with us through other mechanisms. You are therefore advised to read it carefully.
1.3 Terms used within this policy shall have the meaning(s) given to them in the Data Protection Act 2018 (Act) and/or the EU General Data Protection Regulation 2016/679 (Regulation), as applicable.
1.4 By visiting our Website, ThinkTank, Subdomains or other activities in which you participate with us, you understand, accept and consent to the practices described in this policy.
1.5 Any changes we make to this policy will be posted on this page. You are therefore advised to check back frequently as (unless your consent is required in advance of the change), any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
1.6 For more information relating to your rights under this policy, please see section 9.
1.7 If you have any queries relating to this policy, please contact us at contact@3nstrategy.com in the first instance.
2. WHO WE ARE
2.1 For the purposes of the Act, the data controller is 3n Strategy Limited. We are a private limited company registered in England & Wales (company number 08328508) and our registered office is on the 11 thFloor at 12-16 Addiscombe Road, Croydon CR0 0XT.
2.2 We are registered with the ICO to process your personal data and our registration number is ZA537366.
3. YOUR CONSENT
3.1 When you work with us, we do not ordinarily rely on your consent to process your personal data. We will process that personal data to perform our contract with you, and manage our wider working relationship.
3.2 Where you have access to 3n Strategy or ThinkTank data, any personal data associated with your profile will be stored to allow you to access our systems and data.
3.3 We consider that the personal data we obtain is reasonable and necessary for the above listed purposes. However, this is subject to ongoing review and we regularly remove any data that is no longer accurate, or becomes obsolete.
3.4 You may exercise your rights under section 9 at any time, which includes withdrawing your consent to our processing of your personal data. However, where you do not wish to provide your consent in advance, or subsequently wish to withdraw your consent, we may not be able to allow you to continue to use the ThinkTank or to use your interview as part of the relevant project.
4. WHAT WE COLLECT
4.1 Whenever you work with us, we will capture all personal data contained in correspondence with us. This may include your name, email address, telephone number and other contact details, as well as any personal data (names, opinions, comments) contained within the correspondence itself.
4.2 Where you use and access our systems, you may be assigned an account (with various account details unique to you) and a profile (to which you may be able to input your personal data). Your system usage (clickstreams, usage history, etc) may also be monitored.
4.3 Where you participate in any interview, that interview will be recorded and if it is a video interview, your image and facial expressions retained and processed by us. Any comments within that interview will also be stored.
5. HOW WE COLLECT IT
The categories of personal data listed in section 4 are collected in the following ways:
5.1 When you provide it to us
• When setting up your account or profile on our systems;
• When you complete any participation form;
• When you participate in selected event activities
5.2 When we collect it from you
• When you use our Website or the ThinkTank or other systems, we will automatically collect technical information about the device you use to visit. This includes your IP address, browser type/version and related settings.
• We also monitor use of both, including full URLs, pages viewed, how you interact with them and how you exit.
• When you participate in selected research and event activities.
5.3 When provided by someone else
• When your data is provided to us by another individual or business entity, such as (but not limited to) your employer or associated institution (such as a university) providing details to create users, to carry out interviews or other related activities. In these cases the business entity or institution will be authorised to provide your personal data.
• When your data is provided by a partner or service provider. In these cases the business entity or institution will be authorised to provide your personal data.
5.4 Systems we use and where they are based.
• We use a variety of tools to communicate with you, collect and analyse data, host content and more. Your personal data will be held and stored by us in our internal management information systems. These are hosted on servers primarily located in the UK and US.
6. WHAT WE DO WITH IT
6.1 Personal data is primarily required to enable us to supply you with relevant goods, services and support that you have requested from us and to contact you in relation to your enquiries.
6.2 All personal data is processed by 3n Strategy staff or authorized partners and service providers.
6.3 Technical information that we collect about your visit to our websites or use of our systems is used to enable us to:
6.3.1 personalise and improve its functionality and security;
6.3.2 administer and monitor traffic and behaviours for analysis, testing, research, statistical and survey purposes; and
6.3.3 ensure that we can offer you the most effective and efficient browsing experience, to make improvements (where necessary).
6.4 Where you participate in any interview, we will contact you by email to notify you that the relevant report is ready to view, or any upcoming events that we are hosting or involved
6.5 Once collected, your personal data will be retained by us for as long as is necessary to provide you with system access, or to work with you and provide our services to you or to continue to work on the relevant project. Where our working relationship ends, or the project completes, data will be securely deleted and we will not contact you again unless you ask us to.
7. HOW WE KEEP IT SECURE
7.1 Only authorised employees have administrator access to the data processed by it. Rights to grant administrator access are strictly limited to senior management only.
7.2 Personal data can only be accessed by 3n Strategy employees, authorised partners or service providers where there is a business purpose to access it.
7.3 All information is held on remote servers. We do not store personal data in hard copy form.
7.4 We use online cloud storage for online file storage and transfers, maintaining strict security settings. We treat your data as our highest priority, however some providers may process these files which contain your personal data. You should exercise caution when sending sensitive or confidential information via these tools, as documents cannot always be encrypted or password protected, and security cannot be guaranteed at all times.
8. HOW AND WHY WE DISCLOSE IT
8.1 Subject to the rest of this section, the only third parties with, or to, whom we disclose or receive your personal data are authorised 3n Strategy partners or service providers where there is a clear business or legal requirement to do so.
8.2 Any websites linked from the Website or connected to the ThinkTank are outside of our control. They are not covered by this policy and if you access those websites, the operators may collect information from you in accordance with their own independent privacy policies (if any). These may differ from ours, and we cannot accept any responsibility or liability in respect of these.
8.3 Personal data is disclosed in accordance with data acts outlined in section 1.
9. YOUR RIGHTS
9.1 In relation to your personal data that we process at any time, you may ask us to:
9.1.1 clarify what data we hold about you, how we obtained it, to whom it has been disclosed and for how long it will
be stored (to the extent not clarified in this policy);
9.1.2 amend any inaccurate data we hold about you;
9.1.3 provide you with personal data kept on our systems (see 9.2);
9.1.4 delete any of your data (where you no longer consider we need it, or you think we have obtained or processed
it without your consent at any time); and
9.1.5 only process your data in limited circumstances, for limited purposes.
9.2 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file). The time taken to provide the extract may vary depending on the volume of data but will take no more than 30 days from the time of request.
9.3 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy (in the first instance). We will require you to verify your identity to us before we provide any personal data to you, and reserve the right to ask you to specify the types of personal data to which your request relates.
9.4 Where you wish to exercise any of your rights, this may be subject to payment to us of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may only be charged where we reasonably consider your request to be excessive, unfounded or repetitive.