Privacy Policy
Updated 25 July, 2019
This policy identifies why and how Martin Wright Consulting collects and uses your personal data as a data controller.
For services provided by Martin Wright Consulting as a data processor on behalf of our clients please refer to the client’s privacy policy.
You may give your personal details to Martin Wright Consulting directly, such as on an application or contact form, or we may collect them from another source such as a jobs board. Martin Wright Consulting must have a legal basis for processing your personal data. We will only use your personal data in accordance with this privacy policy. At all times we will comply with current data protection laws, including the EU’s General Data Protection Regulation (GDPR) in effect from May 25, 2018.
1. Collection and use of personal data
1.1. PURPOSE OF PROCESSING AND LEGAL BASIS
As a data controller, Martin Wright Consulting may collect and process your personal data (which may include sensitive personal data) for one or more of the following purposes:
• If you register for, and opt in to receive communications from us such as a newsletter, we will use your email address solely for the purpose of sending the eNewsletter to you.
• If you apply for a job or internship at Martin Wright Consulting, whether via our website or via a third party job board, we will use your personal data for the purpose of reviewing your suitability for a role at Martin Wright Consulting, and also for contacting you about future employment opportunities.
• If you contact us via our Contact Form with a general inquiry, we will use your personal data solely for the purpose of responding to your inquiry.
• If you are browsing a Martin Wright Consulting website or web page and have actively consented to the use of Cookies as listed in (5) below, we will use your personal data such as your IP address and geolocation for statistical purposes to analyse how visitors use our website.
In some cases, we may be required to use your personal data for the purpose of investigating, reporting and detecting criminal activity and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon are:
• Your consent, where required;
• Where we have a legitimate interest;
• To comply with a legal obligation that we have;
• To fulfill a contractual obligation that we have with you.
1.2. LEGITIMATE INTEREST
This is where Martin Wright Consulting has a legitimate reason to process your data providing it is reasonable and does not go against what you would reasonably expect from us. Where Martin Wright Consulting has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
• Managing our databases and keeping records up to date;
• Contacting you to seek your consent where we need it.
1.3. STATUTORY/CONTRACTUAL REQUIREMENT
Martin Wright Consulting has certain legal and contractual requirements to collect personal data. If you do not give us personal data we need to satisfy our statutory and contractual requirements we may not be able to continue our relationship with you, or provide services to you that you may have requested.
2. Overseas transfers
Martin Wright Consulting works from time to time with collaborators and may transfer the information you provide to them as required to perform our services to clients. We will take steps to ensure appropriate protections are in place to ensure the security of your information during transfer.
3. Data retention
Martin Wright Consulting will retain your personal data only for as long as is necessary to be able to use it for the reasons given in this privacy policy or for as long as we are required to keep it by law. If you apply for a role at Martin Wright Consulting via our website we may keep your information for the purpose of contacting you should any other opportunities become available; however we will only keep this information for a maximum of 36 months from last contact.
4. Your rights
Your rights under this privacy policy are as follows:
• You have the right to be informed about the personal data that Martin Wright Consulting stores and processes;
• You can ask Martin Wright Consulting for a copy of the personal information that we may be processing or storing;
• You can ask Martin Wright Consulting for information about how we are processing your personal information;
• You can request that we make changes or corrections to the personal data we are storing or processing if it is incorrect or incomplete;
• You can request that Martin Wright Consulting erases any personal information it stores about you;
• You can request that Martin Wright Consulting makes changes to or restricts processing of your personal information (for example, you may wish to unsubscribe from a Martin Wright Consulting e-newsletter);
• You have the right to be notified (as soon as reasonably possible) if Martin Wright Consulting has experienced a data breach involving any of your personal data for which Martin Wright Consulting is the data controller.
EU Citizens have additional data protection rights under the GDPR, including:
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling;
• The right to withdraw consent at any time.
If you would like to exercise any of your rights please contact us via email at [email protected].
If you have specific questions about your personal data in relation to GDPR please email [email protected]
5. Cookies
We may obtain data about you from cookies. These are small pieces of data stored by your browser at the request of websites that you visit, including a user ID the site uses to track the pages you have visited. Cookies are widely used in order to make websites work, or work more efficiently, for ensuring security and to provide information to the owners of the site. Cookies may also be used to deliver more personalised content.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
6. Links to external websites
Martin Wright Consulting’s website may contains links to third-party websites. Please be aware that Martin Wright Consulting is not responsible for the privacy policies of such other sites. When you leave our site we encourage you to read the privacy policies of each and every website that collects personal data. This privacy policy applies solely to information collected through www.martinwrightocnsulting.com.
7. Data security
Martin Wright Consulting uses appropriate technical and organizational measures, including encryption, to protect your personal information and privacy. We protect your personal information using a combination of physical and software security controls, including access controls that restrict and manage the way in which your personal information and data is processed, managed and handled. Whilst we cannot guarantee the security of your personal information, we commit to taking all reasonable steps to do so. Our data security policies and controls are reviewed on a regular basis.
If you have any questions about the security of our website, you can email our Data Security Officer at [email protected].
8. Changes to this privacy policy
We will update this privacy policy from time to time. We will post any changes on the policy with revision dates. If we make any material changes, we will notify you.
9. Questions
If you have questions about any of the processes or procedures set out in this privacy notice please contact: [email protected].
Martin Wright Consulting
Avenida Palma de Mallorca, 66-4
Torremolinos
Malaga, Spain 29620
This policy identifies why and how Martin Wright Consulting collects and uses your personal data as a data controller.
For services provided by Martin Wright Consulting as a data processor on behalf of our clients please refer to the client’s privacy policy.
You may give your personal details to Martin Wright Consulting directly, such as on an application or contact form, or we may collect them from another source such as a jobs board. Martin Wright Consulting must have a legal basis for processing your personal data. We will only use your personal data in accordance with this privacy policy. At all times we will comply with current data protection laws, including the EU’s General Data Protection Regulation (GDPR) in effect from May 25, 2018.
1. Collection and use of personal data
1.1. PURPOSE OF PROCESSING AND LEGAL BASIS
As a data controller, Martin Wright Consulting may collect and process your personal data (which may include sensitive personal data) for one or more of the following purposes:
• If you register for, and opt in to receive communications from us such as a newsletter, we will use your email address solely for the purpose of sending the eNewsletter to you.
• If you apply for a job or internship at Martin Wright Consulting, whether via our website or via a third party job board, we will use your personal data for the purpose of reviewing your suitability for a role at Martin Wright Consulting, and also for contacting you about future employment opportunities.
• If you contact us via our Contact Form with a general inquiry, we will use your personal data solely for the purpose of responding to your inquiry.
• If you are browsing a Martin Wright Consulting website or web page and have actively consented to the use of Cookies as listed in (5) below, we will use your personal data such as your IP address and geolocation for statistical purposes to analyse how visitors use our website.
In some cases, we may be required to use your personal data for the purpose of investigating, reporting and detecting criminal activity and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon are:
• Your consent, where required;
• Where we have a legitimate interest;
• To comply with a legal obligation that we have;
• To fulfill a contractual obligation that we have with you.
1.2. LEGITIMATE INTEREST
This is where Martin Wright Consulting has a legitimate reason to process your data providing it is reasonable and does not go against what you would reasonably expect from us. Where Martin Wright Consulting has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
• Managing our databases and keeping records up to date;
• Contacting you to seek your consent where we need it.
1.3. STATUTORY/CONTRACTUAL REQUIREMENT
Martin Wright Consulting has certain legal and contractual requirements to collect personal data. If you do not give us personal data we need to satisfy our statutory and contractual requirements we may not be able to continue our relationship with you, or provide services to you that you may have requested.
2. Overseas transfers
Martin Wright Consulting works from time to time with collaborators and may transfer the information you provide to them as required to perform our services to clients. We will take steps to ensure appropriate protections are in place to ensure the security of your information during transfer.
3. Data retention
Martin Wright Consulting will retain your personal data only for as long as is necessary to be able to use it for the reasons given in this privacy policy or for as long as we are required to keep it by law. If you apply for a role at Martin Wright Consulting via our website we may keep your information for the purpose of contacting you should any other opportunities become available; however we will only keep this information for a maximum of 36 months from last contact.
4. Your rights
Your rights under this privacy policy are as follows:
• You have the right to be informed about the personal data that Martin Wright Consulting stores and processes;
• You can ask Martin Wright Consulting for a copy of the personal information that we may be processing or storing;
• You can ask Martin Wright Consulting for information about how we are processing your personal information;
• You can request that we make changes or corrections to the personal data we are storing or processing if it is incorrect or incomplete;
• You can request that Martin Wright Consulting erases any personal information it stores about you;
• You can request that Martin Wright Consulting makes changes to or restricts processing of your personal information (for example, you may wish to unsubscribe from a Martin Wright Consulting e-newsletter);
• You have the right to be notified (as soon as reasonably possible) if Martin Wright Consulting has experienced a data breach involving any of your personal data for which Martin Wright Consulting is the data controller.
EU Citizens have additional data protection rights under the GDPR, including:
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling;
• The right to withdraw consent at any time.
If you would like to exercise any of your rights please contact us via email at [email protected].
If you have specific questions about your personal data in relation to GDPR please email [email protected]
5. Cookies
We may obtain data about you from cookies. These are small pieces of data stored by your browser at the request of websites that you visit, including a user ID the site uses to track the pages you have visited. Cookies are widely used in order to make websites work, or work more efficiently, for ensuring security and to provide information to the owners of the site. Cookies may also be used to deliver more personalised content.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
6. Links to external websites
Martin Wright Consulting’s website may contains links to third-party websites. Please be aware that Martin Wright Consulting is not responsible for the privacy policies of such other sites. When you leave our site we encourage you to read the privacy policies of each and every website that collects personal data. This privacy policy applies solely to information collected through www.martinwrightocnsulting.com.
7. Data security
Martin Wright Consulting uses appropriate technical and organizational measures, including encryption, to protect your personal information and privacy. We protect your personal information using a combination of physical and software security controls, including access controls that restrict and manage the way in which your personal information and data is processed, managed and handled. Whilst we cannot guarantee the security of your personal information, we commit to taking all reasonable steps to do so. Our data security policies and controls are reviewed on a regular basis.
If you have any questions about the security of our website, you can email our Data Security Officer at [email protected].
8. Changes to this privacy policy
We will update this privacy policy from time to time. We will post any changes on the policy with revision dates. If we make any material changes, we will notify you.
9. Questions
If you have questions about any of the processes or procedures set out in this privacy notice please contact: [email protected].
Martin Wright Consulting
Avenida Palma de Mallorca, 66-4
Torremolinos
Malaga, Spain 29620