Privacy Policy

1. Personal Data & Data Protection

Q5 Limited (“we” or “Q5”) and its group entities (together the “Group”) collect, and process personal data related to website users.

Q5 are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. In the UK our obligations are primarily in relation to the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. If you are located outside of the UK, we are also committed to meeting our obligations in your location.

This privacy notice sets out the types of data that Q5s hold on you as a website user. It also sets out how Q5 use that information, how long it is kept for and other relevant information about your data. Where local laws impose greater obligations or restrictions on personal data, this Privacy Notice may be supplemented by policies or procedures that are specific to a particular region, country, or entity.

We anticipate Site users to include potential, current and past clients, suppliers, and potential job candidates. If you become a client or apply for a job at Q5 then you will be provided with a separate Privacy Notice to inform you about how we use your data for those purposes. This Privacy Notice is limited to the personal data collected through your use of https://www.q5partners.com/ (the “Site”).

1.1 Data Controllers at Q5

The Data Controller with responsibility for deciding how we collect, use, and store your personal data is Q5 Limited.

Our Global Data Privacy Lead takes responsibility within Q5 for our activities as a data controller.  If you wish to raise any matters relating to this policy or use of your personal data by Q5 you should get in contact using the following details:

Thorney House | 34 Smith Square

London SW1P 3HL

dataprivacy@q5partners.com

2. Data Protection Principles

In relation to your personal data, Q5 will:

• process it fairly, lawfully and in a clear, transparent way;
• only collect your personal data to the extent that is required to fulfil legitimate purposes that have been explained to you;
• only use it in ways that are compatible with the reasons for its collection;
• ensure it is correct and up to date;
• keep your data for only as long as it is needed; and
• use appropriate safeguards to ensure that it is safe and will not be used for anything that you are not aware of or have consented to (as appropriate), or accidentally lost or destroyed.

3. Personal Data Collected

Q5 collects and processes a range of information about you in a variety of ways.

When you create an account on our Site, contact us with an enquiry about our services, take part in a customer/employee satisfaction survey, we may collect personal information about you, including:

• Contact information – your name, email address, marketing preferences and other information that enables us to contact you;
• Employment information – your job title/role, company/employer’s name and other information relating to your employment;
• Enquiry information – information included within and relating to your contact/enquiry; and
• Survey response information – your response(s) to our surveys.

We also collect information about you automatically through your use of the Site. This includes information such as the number and duration of visits to the Site and details of which particular pages have been visited. We will anonymise this information so that it is not attributable to you (“Anonymised Information”).

We also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet for fraud protection, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as cookie, tracking pixel and beacon identification information (“Technical Information”). Please see our Cookies Policy for further information.

We use any collected Technical Information and Anonymised Information to analyse how the Site is functioning and how it is used by users, for insight purposes and to help us maintain and improve the Site on an ongoing basis.

4. The Legal Basis for Personal Data Processing

4.1 To meet legal obligations

Q5 needs to process personal data to comply with numerous legal obligations.

Data protection rights: To keep a record relating to the exercise of any of your rights relating to our processing of your personal information.

4.2 To pursue a legitimate interest

Q5 may process personal data based on a legitimate interest.  This may be your legitimate interest, Q5’s, or a third party’s.  When we rely on legitimate interest as the basis of processing, we will have taken into account your personal interests and fundamental rights and determined whether these override the legitimate interest in processing personal data before, during and after the end of the employment relationship.

Processing necessary for us to promote our business and measure the reach and effectiveness of our campaigns. For marketing purposes (unless consent is required), including to inform you about our promotions and offers by post, email, and telephone. To analyse certain customer behaviours, for example demographics and economic situation to inform our marketing activities, including to target you with offers that we think you may be interested in.

Processing is necessary to manage Q5’s products and service development, improving products and services: To improve our Site and services. To maintain relationships with existing and potential clients, partners, and suppliers. This may include sending newsletters, invitations, updates, and other communications that may be of interest to you or your employer. To process any enquiries made by you.

Processing necessary for us to respond to changing market conditions and the needs of our users. To personalise your experience and to develop the services we offer. To contact you to ask you to take part in customer satisfaction surveys, as part of which we may collect your feedback and contributions. We use this information to develop the services we offer. To ask you to review a service or provide an endorsement.

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively. To ensure that content from our Site is presented in the most effective manner for you and for your device. To allow you to participate in interactive features of our Site, when you choose to do so. For ensuring network and information security. For maintaining records, publishing corporate information and public administration. For fraud prevention and detection purposes. To enforce or defend our legal rights or any claims. As is necessary in conducting a corporate acquisition or disposal, or other transaction. To share your information with third parties for the purposes set out in this Privacy Notice (unless consent is required).

4.3 Consent

We may process your personal data based on your consent:

• To conduct marketing activities where legitimate interests is not relied on.
• To conduct marketing activities using cookies – when you first visit our website you will be asked if you would like to accept all cookies or customise your settings – if you select all cookies this will also enable us to perform marketing activity based on your interactions with the website, other marketing channels and other third parties such as social networks. Please review our Cookie Policy.
• We may post your feedback on our website and in other marketing materials.

You have the right to opt-out of direct marketing at any time. To opt-out, you can: (i) click the unsubscribe button contained in any marketing email which we send to you; (ii) email us at dataprivacy@q5partners.com; or (iii) manage your preferences on the Site.

5. Data Access – Recipients and Transfer

5.1 Data transfers

Q5 is an international business that currently operates in the UK, USA, Australia and the Middle East. Your data may be transferred outside your home country in the operation of the Site and the pursuit of our legitimate interests.

We will implement appropriate safeguards to secure the transfer of your personal data. These safeguards include:

• relying on declarations made by regulators or governments (e.g. adequacy decisions/regulations);
• where an adequacy decision/regulation is not available, the standard contractual clauses approved by relevant regulators or governments, as applicable;
• ensuring that the recipients are subscribed to international frameworks; or
• such alternative measures as are valid and appropriate at the time.

5.2 Sharing data with third parties

Q5 uses third-party processors to assist in the maintenance of the Site. A data processing agreement is in place with all processors to ensure that your personal data continues to be handled confidentially and in accordance with data protection legislation.

We may also disclose personal information to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal information in order to comply with any legal obligation, or in order to enforce or apply our Site terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others.

We will not share your data with third parties for them to send you marketing material without your consent.

When sending your information to third parties, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and (where they are processing personal data as our ‘processor’) not to use it other than in accordance with our specific instructions.

When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

We may disclose your personal information to other third parties as follows:

• any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
• if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.

6. How Q5 Protects Data

Q5 takes the security of your data seriously. Q5 has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by its employees in the performance of their duties and on a “need to know” basis. However, in the unlikely event that there is a data breach, a response plan is in place.

7. How Long Q5 Keeps Data

The length of time for which we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed above.

The only exceptions to this are where the law requires us to hold your personal information for a longer period or delete it sooner.

8. Your Rights

As a data subject, you have a number of rights. You can:

• 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 information we hold about you corrected;
• 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 exercised your right to object to processing (see below);
• object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and the circumstances of your particular situation mean you wish to object to processing on this ground;
• request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
• request the transfer of your provided personal data to another party. In certain circumstances you have the right to request that Q5 sends your personal data to a third party.

If you would like to exercise any of these rights, please contact dataprivacy@q5partners.com.

Please note that certain personal data may be exempt from such access, correction and deletion requests pursuant to applicable data protection laws or other laws and regulations.

We may request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You also have the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights. Q5 does not operate any solely automated decision-making processes. This means that however your data is used and processed, a human being will always be involved. If this ever changes we will let you know the existence of any solely automated decision-making which may have a significant legal impact on you including meaningful information about the logic involved and the consequences we expect this will have on you.

You may also have the right to lodge a complaint directly with the relevant statutory authority in your jurisdiction if you have any concerns about Q5’s processing of your personal data. The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you are not satisfied with our response or believe that Q5 has not complied with your data protection rights, you can make a complaint to the ICO (www.ico.org.uk).

9. Withdrawal of Consent

In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact dataprivacy@q5partners.com.  Once Q5 have received notification that you have withdrawn your consent, your information will no longer be processed for the purpose or purposes you originally agreed to, unless there is another legitimate basis for doing so in law.

10. Contact Us

If you wish to raise a complaint on how we have handled your personal data, you can contact Q5’s Data Privacy Lead at dataprivacy@q5partners.com who will investigate the matter.