Privacy Policy./
The legal stuff.
Background
Napier understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and data subjects and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Napier Technologies Limited.
Limited company registered in England under company number 09901129.
Registered address: 22 Charterhouse Square, London, England, EC1M 6DX
Main trading address: 7th Floor, 30 Churchill Place, London E14 5EU
Data Protection Officer: David Weston (dpo@napier.ai)
Security Officer: Will Fairbanks (william.fairbanks@napier.ai)
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.
5. What Personal Data Do You Collect and How?
Depending upon your use of Our Site or services, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.
Data Collected
How We Collect the Data
Browser Information – including IP address, unique identifiers tied to cookies.
When you browse Our website, we use Cookies and Data Analytics to collect this data.
Contact information – including names, email address, telephone number and address.
When you provide us with information by completing forms, subscribing for email updates or requesting demos.
Business information – including business name, job title, profession.
When you interact with us as part of our marketing and business development activities and by making use of our third-party CRM providers.
Payment Information – including card detail and bank account numbers.
When you make payment to us for services and provide us with your billing information as part of the sales process and by making use of our third-party payment and billing service providers.
Recruitment Information – including, names, email address, telephone number, address, employment history, education history and bank account information.
When you apply for a role at Napier and provide us with information as part of that process (more information can be found in our Candidate Privacy Policy)
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do
What Data We Use
Our Lawful Basis
Site optimisation – we analyse aggregated data to improve website.
Your IP address, unique identifiers tied to cookies.
Legitimate interest – we use insights from browser behaviour to improve the way we market our services.
Marketing – we communicate with you for the purpose specified in opt-out boxes selected by you while competing forms provided on our website. This information is added to, and managed through, our CRM. A member of our sales team may contact you if we determine through your submission that you may be interested in our services. We analyse our CRM data to understand, track, and improve how we market and sell our services (including production of newsletters).
Contact information including names, email address, telephone number and address.
Business information including business name, job title, profession.
Taking steps at your request prior to entering into a contract – If you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis.
Legitimate interests – We will send you our email newsletters being necessary for our legitimate interests to give you information about our products and services (unless you have opted-out). We’ll also retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our service.
Hiring new staff – we may assess your information as part of the hiring process.
Recruitment information including, names, email address, telephone number, address, employment history, education history and bank account information.
Legitimate interests – we want to find the best candidates to join our team.
Sales – our sales team may contact you if you have confirmed you are interested in our services. Our communications are managed through our CRM. We analyse our CRM data to understand, track, and improve how we market and sell our services. We may also add your personal information to our e-signing and billing systems if appropriate.
Contact information including names, email address, telephone number and address.
Business information including business name, job title, profession.
Taking steps at your request prior to entering into a contract – if you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis.
Legitimate interests – we’ll retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our services. We process data in relation to billing and contracting in order to operate the legal and financial elements of our business.
Business Development – we may contact you if you or your business is interested in working with Napier as a potential supplier or partner. This process will be managed by our executive and legal team.
Contact information including names, email address, telephone number and address.
Business information including business name, job title, profession.
Taking steps at your request prior to entering into a contract – If you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis.
Legitimate interests – we want to grow our business and partner with other business to our mutual benefit.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email telephone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data
How Long We Keep It
Browser Information (described above)
Data holding periods are determined by cookie expiry times.
Contact information (described above)
Email newsletters – we store your details until you unsubscribe, at which point we note in our records that you have opted out and won’t send you marketing emails from other sources in future.
Sales process – we retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period.
General – we retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed.
Business information (described above)
Sales process – we retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period.
General – we retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed.
Payment Information (described above)
We may keep your payment information for up to 6 years in order to comply with our legal and taxation requirements.
Recruitment Information (described above)
Information is kept for 1 year after final interview if unsuccessful, or subject to our legal record-keeping requirements if needed for our compliance with immigration law.
8. How and Where Do You Store or Transfer My Personal Data?
We will store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
We will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We may store or transfer some or all of your personal data in countries that are not part of the EEA These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that wewill take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
We may share your personal data with other companies in our group for the purpose of obtaining processional legal and accountancy advice.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. Cookies
Our Site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies – these are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies – these are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies – these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All Cookies used by and on our Site are used in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
- Email address: dpo@napier.ai.
- Postal Address: Data Protection Officer, Napier Technologies Limited, 22 Charterhouse Square, London, England, EC1M 6DX
13. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Notice was last updated on 1 April 2024.
