PRIVACY NOTICE
Publication Date: 10th June 2024
At 6THSENSE, we respect your privacy, and we are committed to protecting your personal data and earning your trust. This Privacy Notice is to give you clarity and transparency on the ways we may use your data. We take reasonable steps to ensure that your data is safe and secure, including putting in place technical safeguards, organizational measures, policies and procedures to comply with applicable laws and regulations.
This Privacy Notice covers the following information:
- Scope of This Notice & Who We Are
- The Data We Collect About You
- How is Your Personal Data Collected?
- How We Use Your Personal Data
- Data Security
- Data Retention
- Your Legal Rights
1. Scope of This Notice & Who We Are
When this Notice Applies
This Privacy Notice applies to the information we collect when auditing or consulting and it includes any personal data whatsoever on any individual or the organization itself.
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how 6THSENSE collects and processes your personal data through your use of the services that we provide.
Our goal is for you to understand:
A. how we look after your personal data when you use our Services.
B. your privacy rights and how the law protects you.
Data Controller
6THSENSE is your data controlling entity for data collected during the execution of our Services. We will seek your formal approval before passing any data pertaining to you to a third party unless said data is subpoenaed by a court of law wherein our compliance with the courts is automatic.
How to Contact Us
We have a Privacy Team responsible for handling all enquiries in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, you may make contact using the details set out below.
Depending on the territory within which you reside, you may also have the right to make a complaint to your regulator of privacy rights or data protection issues. However, before you do so, we would appreciate the chance to deal with your concerns before you approach your regulator, so please contact us in the first instance.
For all queries regarding this Privacy Notice or our privacy practices, please email us at nicole@6thsenserm.com
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. This definition may also extend to personally identifiable information for individuals who have been deceased for less than thirty years.
Personal data shall not be extended to or include any data where identifiable information has been removed (anonymous data) or an individual’s identity is not ascertainable from the data set, whether on its own or combined with other known information.
The information we collect about you and how we collect it may vary depending on the Services that you use, or what we have obtained from a third party with permission to share it with us.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
A. Identity Data
Includes first name, maiden name, last name, pet name or similar identifier, title, date of birth, gender, and copies of your identification card.
B. Contact Data
Includes billing address, delivery address, email address and telephone numbers.
C. Financial Data
Includes any other information provided for the provision of payment services, administration and billing processes.
D. Transaction Data
Includes details about payments to and from you and other details of services you have obtained from us.
We do not knowingly collect data from or about individuals under the legal minimum age without the permission of a parent or guardian. When we do collect that data, we might do it directly. If you believe your child may have provided us with personal information without proper consent, you can contact us and request that we delete the information.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract (to provide you with Services) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (or provide you with a service). In this case, we may have to cancel or terminate the service you have with us, but we will notify you if this is the case at that time.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
A. Direct Interactions
You may give us your Identity, Contact and Financial Data by filling out online forms or by corresponding with us in the office, by post, phone, email or otherwise. This includes personal data you provide when you:
i. use our services.
ii. interact with our website, including making customer enquiries, registering for information or other services.
iii. enter a survey, provide feedback, or respond to communications from us (such as SMS, emails, questionnaires); or
iv. contact us and provide your information online or at our physical location.
B. Automated Technologies or Interactions.
As you interact with our website.
C. Your Use of our Services.
As part of our normal course of business, we generate and collect information concerning your business operations and staff.
D. Third Parties or Publicly Available Sources.
To assist us in providing you with the best service, we may receive and/or share any personal data about you deemed necessary for any of the purposes noted under Section 4.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
A. Where you provide consent to the use of your information. Consent may be withdrawn at any time by notifying us or by terminating or cancelling our service(s).
B. Where we need to perform the contract we are about to enter into or have entered into with you.
C. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, fraud prevention, and improvement of our services.
D. Where we need to comply with a legal obligation such as law enforcement disclosures, or meeting regulatory obligations that are subject to strict internal policies and procedures (such as retention periods).
Purposes for Which We Will Use Your Personal Data We have set out below, in table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis on which we are relying to process your personal data.
Below, please see purpose and use of your personal data:
Purpose/Activity
(a) To register you as a new client
(b) To process and deliver Services
(c) Manage payments, fees and charges
(d) Collect and recover money owed to us
(e) To manage our relationship with you
(f) Marketing and Communications
Type of Data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
Legal Basis for Processing
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(c) Consent
(d) Necessary to comply with a legal obligation
5. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
6. Data Retention
How Long Will You Use My Personal Data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorized 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, regulatory, tax, accounting or other requirements.
Where you have decided to withdraw the consent you have given, we will delete your personal data within 24 hours, unless we are required to keep it for the reasons explained herein. We may need to keep a piece of your contact information, e.g. email address, in our records, so we know that you have withdrawn your consent and therefore ensure we honour your choice.
Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us at nicole@6thsenserm.com.
7. Your Legal Rights
In some countries and under certain circumstances, you have rights 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 your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides 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.
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 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 solely on consent to process your personal data. However, this will not affect the lawfulness of any process 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 enquire about the exercise of any of the rights set out above, please contact the Privacy Team at nicole@6thsenserm.com.
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 will try to respond to all legitimate requests within thirty days. Occasionally it could take us longer 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.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
We endeavour to keep our Privacy Notice under annual review. This version was last updated on 10th June 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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