INTRODUCTION

This privacy policy sets out how SIFA Strategy Limited (collectively referred to as “SIFA Strategy”, “we”, “us” or “our” in this privacy policy) uses and protects any information that you give us when you visit this website.

SIFA Strategy respects your privacy and is committed to ensuring that your personal data is protected. Should we ask you to provide certain information by which you can be identified when using this website or in your engagement with us, it will only be used in accordance with this privacy statement.

We reserve the right to change this policy. Any changes will be posted on this site. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25.05.18.

1.  WHO WE ARE

SIFA Strategy is the data controller and is responsible for your personal data. We are responsible for this website and for managing the data we have in order to conduct our business as a specialist stakeholder engagement, corporate advisory and strategic communications consultancy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us on info@sifastrategy.com

2. DATA AND HOW WE USE IT

Personal data means any information about an individual from which that person can be identified. We may collect, use and store different kinds of personal data depending on your engagement with us.

2.1 Types of data we may collect

Marketing and Communications Data includes correspondence with us and may include contact details such as name, title and email address and any potential preferences as regards receiving communications from us.

We will also collect Usage Data, which includes information about how you use or respond to our products and services, materials or publications or attend or respond to events hosted by us or in partnership with third parties.

Specifically, as it relates to clients, suppliers and employees, we may also gather Contact and Financial Data which could include bank account details, billing address, office address, email and phone number to allow for the normal running of our business and the necessary interactions entailed to maintain contracts we have entered into or are entering into.

We collect and store Survey Data, which includes names, emails and responses to surveys issued on behalf of our clients or our firm. Specific responses are often anonymised, however contact details, including names and email addresses, for respondents will be stored for 18 months before they are deleted in order to allow for delivery of the final product, and to provide continuity for our clients, as appropriate.

As you interact with our website, we may automatically collect Technical Data about your browsing actions and behaviours. We collect this data by using cookies. Please see section 7. Cookie Policy for more information.

Furthermore, we may be required to collect personal data by law, or under the terms of a contract we have with you. Should you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you but we will notify you should this be the case.

2.2 How is this data collected

You may provide us with your personal data by filling in forms, such as the contact form on our website, or by corresponding with us by email, post, phone or otherwise, or through engaging with us as a client, supplier or third party. This includes personal data you provide when you:

• Request delivery or information on our products and services;
• Request marketing materials or reports to be sent to you;
• Attend an event hosted by us or in partnership with a third party;
• Respond to marketing communications from us;
• Fill out the contact form on our website;
• Provide us with feedback; or
• Apply for a job with us.

2.3 How is this data used

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interest, or those of a relevant third party, and your interests and fundamental rights do not override those interests;
• Where we need to perform a contract which we have entered or are about to enter into;
• Where we need to comply with a legal or regulatory obligation;
• Where it is necessary to send communications on behalf of clients, in accordance with the law;
• For internal record keeping purposes to allow us to improve our products and services or to better tailor our marketing materials and reports to you.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may however have to share your personal data with the parties set out below:

• External Third Parties who may have access to some data as part of their engagement with us. These parties currently include our external IT provider and an external provider of research services.
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or assets.

We expect all third parties to respect the security of your personal data and treat it in accordance with the law and in any event, would not allow any third-party service providers to use your personal data for their own purposes.

3. DATA SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. In addition, we limit access to your personal data to those employees, and in rare cases other third parties, who have a professional need to know. They will only process your personal data in accordance with our instructions and are subject to a duty of confidentiality.

In the event of any suspected personal data breach, we will notify you and the UK Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues, of a breach where we are legally required to do so.

4. DATA RETENTION

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, the interests related to the data, and the applicable legal requirements.

Unless you opt-out or we receive a request to delete personal data or cease communcation with you we will keep and update Marketing and Communications Data.

5. OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us on info@sifastrategy.com, in writing, at any time.

Where you opt out of receiving our marketing messages or other communications, this opt-out will not apply to personal data provided to us as a result of a product/service purchase/delivery or other transaction. In these instances, we will often be required by law to retain your data.

You may also choose to restrict the collection or use of your personal information by choosing to unselect the box that enables us to use your information for direct marketing purposes when filling in the contact form on the website. In other circumstances, please be in touch with us direct, at any time on info@sifastrategy.com.

6. YOUR RIGHTS / CONTROLLING YOUR PERSONAL DATA

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These individual rights are best summarised by the ICO here: Read More

You will not have to pay a fee to access your personal data, or to exercise any of the other fundamental rights. However, we do reserve the right to charge a reasonable fee, or may refuse to comply, if your request is unfounded.

You may request details of personal information which we hold about you at any time. If you would like a copy of the information held on you please write to info@sifastrategy.com. We will 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.

If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible on info@sifastrategy.com. We will promptly correct any information found to be incorrect.

Please be aware that we may also need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data, or to exercise any of your other fundamental rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to it. We may also contact you to ask you for further information in relation to your request to accelerate our response.

You have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

7. COOKIE POLICY

As mentioned previously in our Privacy Policy, as you interact with our website, we may automatically collect Technical Data about your browsing actions and behaviours. We collect this data by using cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Most web browsers will automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please be aware that this may prevent you from taking full advantage of the websites your interact with.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

7.1 Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.