Privacy Policy
BACKGROUND
Exotopic 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 employees, partners and clients 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
Exotopic Limited, company registered in the UK under company number 09238982.
Registered address: 2nd Floor British Interplanetary Society, 27/29 South Lambeth Road, London, England, SW8 1SZ
Data Protection Officer: Andy Grey
Email address: andy.grey@exotopic.com
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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.
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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.
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4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
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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 1.
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The right to access the personal data we hold about you. Part 10 will tell you how to do this.
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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 1 to find out more.
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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 1 to find out more.
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The right to restrict (i.e. prevent) the processing of your personal data.
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The right to object to us using your personal data for a particular purpose or purposes.
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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.
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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.
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Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
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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 1.
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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 1.
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5. What Personal Data Do You Collect and How?
Depending upon your use of Our 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. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.
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Data Collected: Identity Information, including name, date of birth and gender
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How We Collect the data: We collect data directly from the data subject.
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Data Collected: Contact information, including address, email address and telephone number
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How We Collect the data: We collect data directly from the data subject.
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Data Collected: Business information, including business name, job title, profession.
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How We Collect the data: We collect data directly from the data subject.
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Data Collected: Payment information, including bank account numbers.
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How We Collect the data: We collect data directly from the data subject.
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6. How do you use my 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:
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What we do: Administering our business.
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What Data We Use: Identity and Business Information.​
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Our Lawful Basis: With consent of the data subject, it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
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What we do: Supplying our services to you.
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What Data We Use:​ identity and Business Information.
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Our Lawful Basis: With consent of the data subject, it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
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What we do: managing payments for our services.
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What Data We Use:​ Payment Information.
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Our Lawful Basis: With consent of the data subject, it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
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What we do: Communicating with you.
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What Data We Use:​ Contact Information.
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Our Lawful Basis: The data subject has given consent to the processing of their personal data for one or more specific purposes.
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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 1.
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.
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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 used to determine how long it is kept):
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Type of Data: Identity information including name, date of birth and gender.
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How long We Keep it: The retention period will be determined by the length of time it is required to fulfil the relevant project's objectives, or the employee's period of employment.​
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Type of Data: Contact information including address, email address and telephone number.
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How long We Keep it: The retention period will be determined by the length of time it is required to fulfil the relevant project's objectives, or the employee's period of employment.
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Type of Data: business information including business name, job title, profession.
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How long We Keep it: The retention period will be determined by the length of time it is required to fulfil the relevant project's objectives, or the employee's period of employment.
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Type of Data: Payment information including bank account numbers.
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How long We Keep it: The retention period will be determined by the length of time it is required to fulfil the relevant project's objectives, or the employee's period of employment.
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8. How and Where Do You Store or Transfer My Personal Data?
We will store or transfer 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 we will 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 within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on bind
Please contact us using the details below in Part 1 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
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:
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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;
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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;
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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.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with the following third parties to supply services.
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Recipient: Credence.​
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Activity Carried Out: Background Screening.
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Sector: Background Screening Market.
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Location: UK.
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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
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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 1. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
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 48 hours 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.
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11. 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. Any changes will be made available via our website at www.exotopic.com
This Privacy Notice was last updated on 17/06/24.