We understand that your privacy and the security of your personal information is extremely important. As a company we are committed to protecting your privacy when you visit our website, use our spikizi app, provide your details for our services, or interact with us in any way. It is important to us to respect your privacy in everything we do and ensure that you are always clear on how your personal information is used.

In this Privacy Notice we will explain what personal information we collect, what we do with it and how we secure your information. We will also explain your rights in relation to the personal information we hold about you and how you can exercise your rights or register a complaint.

Contact details:

Carbon Global Limited, 84 Bridport Place, London, England, N1 5DS.

Registered Company Number 10784684

Registered Company Number 10784684

Data Protection Officer: henry@carbonglobal.co.uk

Personal information we collect:

We only collect information we need to provide our services. We currently collect and process the following personal information:

a). Name and Surname

b). Address (physical/postal)

c). Telephone number

d). Gender and Age

e). Email address

f). IP address and browser data

g). Driver’s licence if we require proof of your identity

h). Passport details if we require proof of your identity

i). Bank details or card details if you make a payment or we need to pay for services

j). Photographs

k). Comments and notes relating to you

l). Location data

m). Education details

n). Voice recordings

Sensitive and Special Category Information:

When using our spikizi app we collect personal information classified as special category and sensitive data with your explicit consent. This information includes racial or ethnic origin, religious or philosophical beliefs and biometric data of voice recordings that can, in some cases, uniquely identify you.

You are under no obligation to provide any information but if you do not, then it might be impossible for us to provide our services and fulfil our contract with you. In some cases, we have a legal obligation to collect your personal information.

How we obtain and use personal information:

Most of the personal information we process was provided directly by you for one of the following reasons:

a. Providing a quote for a service.

b. Providing our contracted services.

c. Background information to research prospects for business development.

d. To respond to enquiries, correspondence or contact requests.

e. You agreed to receive marketing communications from us.

f. When using our website or our spikizi app.

g. You provided products or services to us.

In some cases, information may be provided to us by a business partner or vendor as part of a contracted service or when researching for our business development service.

Legal basis for processing personal information:

As a company we provide different services and our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the type of personal information and the specific context in which we collect and use it.

We will normally collect and process your personal information only when you have given your consent or when we are providing our services as part of our contractual obligations.

In some cases, the processing of your personal information may be based on our legitimate interest as a company but not when overridden by your data protection interests or fundamental rights and freedoms. We may also have a legal obligation to collect personal information to meet our statutory obligations.

We always process personal data legally as required by law. The different legal bases we rely on are:

a. Consent: You gave permission to process the information for a specific purpose. You can remove your consent at any time by contacting our Data Protection Officer.

b. Legitimate Interests: The processing is necessary to provide our services to our clients.

c. Performance of a Contract: We must process personal information in order to meet our contractual obligations.

d. Vital Interests: In an emergency we might provide personal information to save someone’s life.

e. Legal Obligation: We are required to process your personal information by law.

f. Public Interest: To carry out a task in the public interest.

What we do with the information:

We use personal information in the following ways as part of our business operations:

a. To provide quotes for our services.

b. To provide our research, voice and business development services.

c. To personalise your browsing experience and monitor trends on our website and app (please see our Cookie Notice).

d. To promote our company and services.

e. To meet our obligations to our suppliers.

f. To contact you, following your enquiry or reply to questions.

g. To deal with complaints.

h. To provide information legally required by law or to fulfil a contract.

i. To provide benefits to users of our spikizi app.

Sharing of Information:

We do not share information with third parties unless you have given your permission, we have notified you or we are legally required to do so. In most cases the sharing will be related to the contracted services we provide to you. It might be required to share information with our professional advisors or data processors. We may share your information with group companies to provide you with information about our products and services available from them. We may provide anonymous aggregated data on a commercial basis.

If you are making use of our spikizi app, we may share your personal information, including voice recordings, with linguistic researchers and potential employers. We do not transfer personal information outside of the EEA and if such a transfer might become necessary, we will ensure that standard contractual clauses or other transfer safeguarding measures are used and that you are aware of this transfer.

Cookie Notice:

We use cookies to enhance your browsing experience, recognise you when you return and to generally ensure efficient functionality. Cookies are small files normally consisting of letters and numbers which store information on the user’s device. We also have links on our website and app to other websites and to social media sites. Some of the cookies are classified as non-essential cookies which you can decline. Strictly necessary cookies are required to enable the functioning of the website.

How we store your information:

We have put in place appropriate organisational and technical measures to meet our legal obligation to ensure the security of your personal information. All information you provide to us is stored on our secure servers. We use industry standard security and firewalls on our servers and encrypted computer devices. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Only authorised personnel and contractors have access to your information.

We keep personal information for only as long as necessary for our business purposes and to meet our legal and contractual obligations. In most cases, our retention period will come to an end when we no longer require your information. Inactive accounts will be deleted seven years after the subscription ends and special category data will be removed two years after the end of your subscription. Personal information linked to voice recordings will be deleted seven years after your subscription ends but the recordings will be retained for a longer period to meet ongoing contractual, research and legal obligations.

We review personal information we hold every two years to establish if it is still necessary for us to store and that the information we hold is accurate. We dispose of information by deleting it from all our systems and securely disposing of paper files. Please contact our Data Protection Officer for more information on our retention periods.

Your data protection rights:

Under data protection law, you have rights pertaining to your personal information, including:

a) . Your right of access - You have the right to ask us for copies of your personal information.

b) . Your right to rectification - You have the right to ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

c) . Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. We maintain a retention policy and will inform you if we are not able to delete your information immediately.

d) . Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

e) . Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

f) . Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

g) . Rights in relation to automated decision making and profiling.

You do not need to pay a fee for exercising your rights. If you make a request, we are required to respond to you within one month unless there are reasons why it will take longer to collect the information you requested. If that is the case, we will inform you. In some cases, we will require you to provide proof of your identity through a driver’s licence or passport if we are unable to confirm your identity through other information we hold about you. This is required to ensure the security of the personal information we hold and to meet our legal obligations.

Please contact our Data Protection Officer if you want to exercise any of your rights.

How to complain:

In the first instance please send complaints to our Data Protection Officer. If you are not happy with the response you receive from us or how we use your information, please send your complaint to the Information Commissioner’s Office (ICO).

Information Commissioner’s Office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline number: 0303 123 1113 www.ico.org.uk

From time to time we may add or change functions, features or products to our website, the spikizi app or add or change our services. This, and our commitment to protecting the privacy of your personal information, may result in periodic changes to this Privacy Notice. If we make any material changes to this Privacy Notice, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website or app.

Last updated August 2020