Privacy Policy

Introduction

This Privacy Policy (the “Policy”) explains how Aspirant Analytics (“we”, “us”, “our”) may process your Personal Data. Pirical is a trading name of Aspirant Analytics Ltd. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. Defined terms are given the meaning in Section 18.

1. Aspirant Analytics, the Controller and Data Protection Officer

1.1 Aspirant Analytics is a limited company registered in England and Wales (Company Number 08406864) whose registered office is 20-22 Wenlock Road, London, N1 7GU, United Kingdom.

1.2 For the purposes of this Policy, Aspirant Analytics is the Controller.

1.3 Many of the capitalised terms used in the Policy derive their meaning from defined terms in applicable data privacy law and we use those terms in the same way as they are used in applicable data privacy law. The definitions of the terms which are capitalised in this Policy are in Section 18 below. If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact our Data Protection Officer:

Hok-Him Poon 
20-22 Wenlock Road
London
N1 7G
UUnited Kingdo
mhok-him@pirical.com

2. Collection of Personal Data 

We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you subscribe to any of our Services); when you make your Personal Data public (e.g., if you make a public post about us on social media); when you use any of our Software; when you visit our Sites; when you register to use any of our Sites, Software, or Services. We may also receive Personal Data about you from third parties (e.g. as part of our people analytics service known as “Pirical On Demand” and from credit reference agencies and regulatory bodies). See below for more detail on the way in which we collect your Personal Data.
We may collect Personal Data about you from the following sources:

2.1 When you provide Personal Data: we may collect or obtain your Personal Data when you register to use our Sites, Software and Services and each time you contact us via e-mail, telephone or any other means.

2.2 Through our relationship with you: we may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., if you purchase a Service from us).

2.3 Data you make public: we may collect or obtain your Personal Data that you manifestly choose and/or consent to make public, including via social media, employer websites, regulatory bodies etc.

2.4 Site and Software data: we may collect or obtain your Personal Data when you visit any of our Sites and/or use any features or resources available on or through a Site and/or any features or resources available through our Software.

2.5 Registration details: we may collect or obtain your Personal Data when you use, or register to use, any of our Sites, Software or Services.

2.6 Third party information: we may collect or obtain your Personal Data from third parties who provide it to us (e.g., as part of our people analytics service known as “Pirical On Demand” and from credit reference agencies and regulatory bodies).

3. Use of Cookies and other tracking technology

We may Process your Personal Data by placing or reading Cookies. We may use Cookies and/or similar tracking technology to: authenticate your identity, check your status, personalise the Service, ensure the security of our Sites, Software and Services and for analysis.

3.1 When you visit a Site or use our Software we may place Cookies onto your device, or read Cookies already on your device.

3.2 We use cookies for the following purposes:

3.2.1 authentication ✅ - we use cookies to identify you when you visit and navigate our Sites and/or use our Software;

3.2.2 status 💡 - we use cookies to help us determine if you are logged into our Sites and/or Software and record information about your device and your browser;

3.2.3 personalisation 🎨- we use cookies to store information about your preferences and to personalise our Sites and/or Software;

3.2.4 security 🔐 - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our Sites, Software and Services generally; and

3.2.5 analysis 🕵️‍♀️- we use cookies to help us to analyse the use and performance of our Sites, Software and/or Services.

3.3 You can control and/or delete several types of cookies. For details, please see www.aboutcookies.org. For example, you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. You can further delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

We may set the following cookies:

4. Creation of Personal Data

We may also create Personal Data about you, such as records of your interactions with us, and details of any Services agreed between you and us.

5. Processing of Personal Data

We may Process: your personal details (e.g., your name); your contact details (e.g., your office phone number and office email address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Software (e.g., the type of device you are using); and details of your employer (where relevant); and any views or opinions you provide to us.

We may Process the following categories of Personal Data about you:

5.1 Personal details: given name(s); title, name and position;

5.2 Contact details: office address; office telephone number; email address;

5.3 Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);

5.4 Purchase details: records of purchases and prices;

5.5 Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques;

5.6 Data relating to our Sites and Software: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; Software usage statistics; Software settings; dates and times of connecting to our Software; location data, IMEI address (a unique number assigned to mobile phones that is used by GSM networks to help them identify valid mobile devices) or UDID (unique device identifier) and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information;

5.7 Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant; and

5.8 Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

5.9 Information about your employment: including data relating to your time at your employer and progression at your employer.

6. Lawful Basis for Processing of Personal Data

We may Process your Personal Data where: you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; or where we have a valid legitimate interest in the Processing for the purpose of managing, operating or promoting our business (and where that legitimate interest is not overridden by your interests, fundamental rights or freedoms).

6.1 In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

6.1.1 Consent: we may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or Processing that we are under an obligation to carry out);

6.1.2 Contractual necessity: we may Process your Personal Data where the Processing is necessary in connection with any contract that you have entered into or may enter into with us;

6.1.3 Compliance with applicable law: we may Process your Personal Data where the Processing is required by applicable law; or

6.1.4 Legitimate interests: we may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection legislation. Our legitimate interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

6.2 If you have any concerns about our Processing you have the right to object to Processing that is based on our legitimate interests. For more information on your rights, please see “Your Legal Rights” at Section 16 below.

7. Purposes for which we may Process your Personal Data

We may Process your Personal Data for the following purposes: providing services to you; operating our Sites and Software; communicating with you; managing our IT systems; financial management; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Sites, Software, and Services.

The purposes for which we may Process Personal Data, subject to applicable law, include:

7.1 Provision of Services to you: providing our Sites, Software, or Services to you; providing you with Services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those Services;

7.2 Provision of Services to your employer: providing our people analytics services to your employer;

7.3 Our Sites and Software: operating and managing our Sites and Software; providing content to you; communicating and interacting with you via our Sites and Software; and notifying you of changes to any of our Sites, our Software, or our Services;

7.4 Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items, new Software and Services and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required;

7.5 Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits;

7.6 Financial management: sales; finance; corporate audit; and vendor management.

7.7 Surveys: engaging with you for the purposes of obtaining your views on our services;

7.8 Security: electronic security (including login records and access details);

7.9 Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;

7.10 Legal proceedings: establishing, exercising and defending legal rights;

7.11 Legal compliance: compliance with our legal and regulatory obligations under applicable law; and/or

7.12 Improving our Sites, Software, Services: identifying issues with our Sites, our Software, or our Services; planning improvements to our Sites, our Software, or our Services; and creating new Sites, Software, or Services.

8. Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

8.1 Establishment, exercise or defence of legal rights: we may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; and/or

8.2 Consent: we may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

9. Disclosure of Personal Data to Third Parties

We may disclose your Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites, or Software.

9.1 We do not sell, trade or otherwise transfer your Personal Data to third parties for marketing purposes without your consent. We may disclose your Personal Data to:

9.1.1 legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

9.1.2 accountants, auditors, lawyers and other outside professional advisors to Aspirant Analytics, subject to binding contractual obligations of confidentiality;

9.1.3 third party Processors (such as payment services providers or other providers of services to us located anywhere in the world). These third party Processors are required to Process your Personal Data to carry out the provision of service to us. However, we will enter into a written agreement which will impose obligations on the service provider to protect your Personal Data and not to Process it except in accordance with our instructions and subject to applicable laws or regulations;

9.1.4 your employer as part of our people analytics services;

9.1.5 any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

9.1.6 any relevant party where we are obliged to do so in connection with the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security; and/or



9.1.7 any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

10. International Transfer of Personal Data

We may transfer your Personal Data within Aspirant Analytics, and to third parties as noted in Section 10, in connection with the purposes set out in this Policy. We may transfer your Personal Data for such reasons to other countries that are considered to be Adequate Jurisdictions - please note, this may mean these countries have different laws and data protection compliance requirements to those that apply in the country in which you are located.

11. Data Security

We have appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. 

The transmission of information via the internet is not completely secure given that it is an open system. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

12. Data Accuracy 

We take reasonable steps to ensure that:

12.1 Your Personal Data that we Process are accurate and, where necessary, kept up to date; and

12.2 Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay

From time to time we may ask you to confirm the accuracy of your Personal Data.

13. Data Minimisation

We take reasonable steps to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

14. Data Retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. However, the period of time for which we hold your Personal Data will vary depending upon the type of information and the reason why we Process it.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

15. Your Legal Rights

Under applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:

15.1 the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Software, or our Services, if you do not provide us with your Personal Data – e.g., we may not be able to deliver our Services without the necessary details); 

15.2 the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data; 

15.3 the right to request rectification of any inaccuracies in your Relevant Personal Data; 

15.4 the right to request, on legitimate grounds: 

15.4.1 erasure of your Relevant Personal Data; or 

15.4.2 restriction of Processing of your Relevant Personal Data; 

15.5 the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf; 

15.6 the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable; 

15.7 where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and 

15.8 the right to lodge complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf. This does not affect your statutory rights.

16. Exercising Your Legal Rights

16. To exercise one or more of the legal rights in Section 15, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please contact our Data Protection Officer whose details are provided in Section 1.3. Please note that:

16.1 We may require proof of your identity before we can give effect to these rights; and

16.2 Where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

17. Terms of Service

All use of our Sites, our Software, or our Services is subject to our Terms of Service. We recommend that you review our Terms of Service regularly, in order to review any changes we might make from time to time.

18. Definitions

“Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs and any other tracking devices.

“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.

“Services” means the services provided under any applicable agreement between Us and you which includes use of our Sites and/or Software.

“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

“Software” means any application, software or platform made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

“Site” means any website operated, or maintained, by us or on our behalf.