Quinjo will need to collect and hold your personal information in order to provide you were services. This Privacy Notice describes the information Quinjo collects about you, how it is used and shared, and your rights regarding it. Accordingly, please read the following information carefully.

Data Controller

Quinjo is registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that it holds and processes as a provider of software and services. Its registered address is 20-22 Wenlock Road London N1 7GU, and its registration number is 11011420. Quinjo also acts as a Data Processor for its customers.

Information collected

Quinjo may collect personally identifiable information when you visit our website, fill out online contact forms, complete surveys, sign up to our email marketing list, contact us directly over the phone or in writing, when you purchase Quinjo products or services and when you apply for jobs at Quinjo.

We will collect some or all of the following personal information that you provide:

·         personal details (including date of birth, email address, IP address, telephone number, address and other contact details which may include social media, type of browser used and type of device used to access Quinjo services )

·         associations with companies that are Quinjo customers

·         files and data that you have created and/or accessed  using Quinjo products or services.

·         goods and services

·         financial details

·         education, training and employment details

·         physical or mental health details

·         racial or ethnic origin

·         political opinions

·         religious, philosophical or other beliefs

·         trade union membership

·         sex life or sexual orientation

·         genetic information

·         biometric information for the purpose of uniquely identifying a natural person

·         criminal proceedings, outcomes and sentences, or related security measures

·         other personal information relevant to instructions to provide legal services, including information specific to the instructions in question

·         medical records

·         Social Services records.

Information collected from other sources

The same categories of information may also be obtained from third parties, such as experts, members of the public, your officers or employees or business contacts, your family and friends, witnesses, courts and other tribunals, suppliers of goods and services, investigators, government departments, regulators, public records and registers.

How We use your personal information: Purposes

We may use your personal information for the following purposes:

·         to provide you with the services which you have agreed that Quinjo will provide and / or for any purposes ancillary to those services

·         to promote and market Quinjo services (where you have expressly consented to Quinjo using your data in this way)

·         to communicate with you about news, updates and events (where you have expressly consented to Quinjo using your data in this way)

·         to assist in training of staff and/or customers and/or prosective customers

·         to investigate and address your concerns or complaints

·         to investigate or address legal proceedings relating to your use of Quinjo services/products, or as otherwise allowed by applicable law

·         to carry out anti-money laundering and terrorist financing checks

·         as otherwise required or permitted by law

Marketing and promotion

In relation to personal information collected for marketing purposes, the personal information consists of:

·         names, contact details, and name of organisation

·         the nature of your interest in Quinjo marketing

·         your attendance at Quinjo events.

This will be processed so that you can be provided with information about Quinjo can invite you to events. You may contact Quinjo using the contact details at the end of this document if you no longer wish to receive such invitations or information.

The legal basis for processing your personal information

Quinjo relies on the following as the lawful bases to collect and use your personal information:

·         If you have consented to the processing of your personal information, then Quinjo may process your information for the Purposes set out above to the extent to which you have consented to Us doing so.

·         In relation to information which is in categories (a) to (f) above, Quinjo relies on:

o   The necessity of processing that data for the performance of any contract between yourself or an entity connected with you and Quinjo

o   The legitimate interests of Quinjo or a third party in carrying out the processing for the Purposes set out above

o   Where necessary in order that Quinjo can comply with a legal obligation to which Quinjo are subject (including carrying out anti-money laundering or terrorist financing checks)

·         In relation to information in categories (g) to (r) above (these being categories which are considered to include particularly sensitive information and which include information about criminal convictions or proceedings), Quinjo is entitled by law to process the information where the processing is necessary for legal proceedings, legal advice, or otherwise for the establishment, exercise or defence of legal rights, providing that one of the lawful bases set out above is also established.

Who will Quinjo share your personal information with?

It may be necessary to share your information with the following:

·         information processors, such as IT support staff, email providers, information storage providers and OCR providers.

·         companies who work on behalf of Quinjo to provide a product or service to you (unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us)

·         persons or organisations which Quinjo needs to share information with to provide the product or service you or your organisation has requested

·         regulatory authorities

·         current, past or prospective employers

·         education and examining bodies

·         legal professionals

·         experts and other witnesses or potential witnesses

·         prosecution authorities

·         courts and tribunals

·         Quinjo staff including employees, officers and sub-contractors

·         family and associates of the person whose personal information Quinjo is processing

·         business associates, professional advisers and trade bodies,

·         the email provider that we use to communicate with you

·         the general public in relation to the publication of legal judgments and decisions of courts and tribunals

Quinjo may be required to provide your information to regulators, such as the Financial Conduct Authority or the Information Commissioner’s Office. In the case of the Information Commissioner’s Office, there is a risk that your information may lawfully be disclosed by them for the purpose of any other civil or criminal proceedings, without Our consent or your consent, which includes privileged information.

Quinjo may also be required to disclose your information to the police or intelligence services, where required or permitted by law.

Sources of information

The personal information Quinjo obtain may include information obtained from:

·         legal professionals

·         experts and other witnesses

·         prosecution authorities

·         courts and tribunals

·         lay and professional clients of you or your organisation

·         family and associates of the person whose personal information Quinjo is processing

·         other regulatory authorities

·         current, past or prospective employers

·         education and examining bodies

·         business associates, professional advisers and trade bodies, e.g. the Bar Council

·         the general public in relation to the publication of legal judgments and decisions of courts and tribunals

·         data processors, such as IT support staff, email providers, data storage providers

·         public sources, such as the press, public registers and law reports

Transfer of your information outside the European Economic Area (EEA)

If you reside or are based outside the EEA then it may be necessary to transfer some of your information to that country outside of the EEA for that purpose. If you are in a country outside the EEA then it is inevitable that information will be transferred to those countries. If this applies to you and you wish additional precautions to be taken in respect of your information please indicate this when providing initial instructions.

Some countries and organisations outside the EEA have been assessed by the European Commission and their information protection laws and procedures found to show adequate protection. The list can be found here. Most do not. If your information has to be transferred outside the EEA, then it may not have the same protections and you may not have the same rights as you would within the EEA.

We may transfer your personal information to the following which are located outside the European Economic Area (EEA):

·         Cloud information storage services based in the USA who have agreed to comply with the EU-U.S. Privacy Shield, in order to enable Quinjo to store your information and/or backup copies of your information so that Quinjo may access your information when they need to, and for the purposes of Optical Character Recognition. The USA does not have the same information protection laws as the EU but the EU-U.S. Privacy Shield has been recognised by the European Commission as providing adequate protection. To obtain further details of that protection see https://ec.europa.eu/info/law/law-topic/information-protection/information-transfers-outside-eu/eu-us-privacy-shield_en

·         Cloud information storage services based in Switzerland, in order to enable Quinjo to store your information and/or backup copies of your information so that Quinjo may access your information when it needs to. Switzerland does not have the same information protection laws as the EU but has been recognised by the European Commission as providing adequate protection; see https://ec.europa.eu/info/law/law-topic/information-protection/information-transfers-outside-eu/adequacy-protection-personal-information-non-eu-countries_en

We will not otherwise transfer personal information outside the EEA except as necessary for the conduct of any legal proceedings.

If you would like any further information please use the contact details at the end of this document.

How long will We store your personal information?

We will normally store all your information:

·         Until at least 6 years after the expiry of any relevant limitation period, e.g. from the date of the last provision of Quinjo services or goods. This is because it may be needed for potential legal proceedings. At this point any further retention will be reviewed and the information will be marked for deletion or marked for retention for a further period. The latter retention period is likely to occur only where the information is needed for legal proceedings, regulatory matters or active complaints. Deletion will be carried out as soon as reasonably practicable after the information is marked for deletion.

·         Equality and diversity data may be retained for the same period in pseudonymised form for the purpose of research and statistics and complying with regulatory obligations in relation to the reporting of equality and diversity data.

·         Names and contact details held for marketing purposes will be stored indefinitely or until Quinjo becomes aware or is informed that the individual has ceased to be a potential client.

Consent

In circumstances where Quinjo has obtained your consent in order to process personal data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity carried out prior to you withdrawing your consent. However, where Quinjo also relies on other bases for processing your information, you may not be able to prevent processing of your information.

If there is an issue with the processing of your information, please contact Quinjo using the contact details below.

Your Rights

·         Under the GDPR, you have a number of rights that you can exercise in certain circumstances. These are free of charge. In summary, you may have the right to:

·         Ask for access to your personal information and other supplementary information;

·         Ask for correction of mistakes in your information or to complete missing information Quinjo holds on you;

·         Ask for your personal information to be erased, in certain circumstances;

·         Receive a copy of the personal information you have provided to Us or have this information sent to a third party. This will be provided to you or the third party in a structured, commonly used and machine-readable format, e.g. a Word file;

·         Object at any time to processing of your personal information for direct marketing;

·         Object in certain other situations to the continued processing of your personal information;

·         Restrict the processing of your personal information in certain circumstances;

If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR.

If you want to exercise any of these rights, please:

·         Use the contact details at the end of this document;

·         Quinjo may need to ask you to provide other information so that you can be identified;

·         Please provide a contact address so that you can be contacted to request further information to verify your identity;

·         Provide proof of your identity and address;

·         State the right or rights that you wish to exercise.

We will respond to you within one month from when we receive your request.

 

Marketing Emails

Please note if you wish to unsubscribe from any marketing emails that you have signed up for, you can do so by emailing cXXXXX It may take up to 7 days for this to become effective.

How to make a complaint?

The GDPR also gives you the right to lodge a complaint with the Information Commissioners’ Office if you are in the UK, or with the supervisory authority of the Member State where you work, normally live or where the alleged infringement of information protection laws occurred. The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/.

Automated Decision Making

We do not use automated decision making.

Future Processing

Quinjo does not intend to process your personal information except for the reasons stated within this privacy notice. If this changes, this privacy notice will be amended.

Changes to this privacy notice

This privacy notice was published on 1 April 2020 and last updated on 1 April 2020

Quinjo continually reviews its privacy practices and may change this policy from time to time. When we do an amended privacy notice will be placed on Quinjos’ website.

Contact Details

If you have any questions about this privacy notice or the information We holds about you, please contact Us using the contact details below.

The best way to contact Quinjo is by email at admin@quinjo.com, or by telephone on 0844 5676567