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Privacy notice

Last updated

This notice explains what personal data we collect through this website, why we collect it, who we share it with and the rights you have over it.

Who we are

Constancia Holdings Limited runs this website and trades as Constancia. We are the controller of the personal data this notice describes, which means we decide how and why it is used.

Constancia Holdings Limited
Registered in England and Wales, company number 17227112
Blount House, Hall Court, Hall Park Way, Telford, Shropshire, TF3 4NQ
info@constancia.io

We are not required to appoint a data protection officer. Any question about this notice or your data can go to info@constancia.io.

This website is for businesses. It is not aimed at children, and we do not knowingly collect data about anyone under 18.

What we collect

We collect personal data in 3 ways:

  • when you give it to us through the contact form, the newsletter sign up or an email
  • when you use the site, through the analytics and advertising tools that section 6 describes
  • when you register for 1 of our events on Luma, which shares your registration with us

What you give us

  • your work email address, name, company, role and job title
  • what you need help with, how many legal entities your group has and when the work needs to be live
  • anything you write in an email to us

What the site records

  • the pages you visit and how long you spend on them
  • the page that sent you here and any campaign tags in the link
  • your browser, your device type and your approximate location from your IP address
  • the requests your browser makes, which our host logs to keep the site secure

We do not ask for, and do not want, any special category data such as health, religion or political views.

How we use it and why

The law says we need a lawful basis for each use of your data. This table sets out each purpose and the basis we rely on.

PurposeDataLawful basis
Reply to your enquiry and prepare a proposalWhat you send through the form or by emailLegitimate interests in answering a business enquiry, or steps you ask us to take before a contract
Send your enquiry to the right personYour role, your need, your entity count and your timelineLegitimate interests in replying quickly and well
Send you The Sunday CloseYour email address and first nameConsent
Understand how the site is used and improve itStatistics on visits, pages and devicesLegitimate interests in running a useful website
Measure and target our advertisingAdvertising cookie dataConsent
Keep the site and the form secureYour IP address and request logsLegitimate interests in protecting the site
Keep business records and meet our legal dutiesRecords of work, contracts and invoicesLegal obligation

Where we rely on legitimate interests, we have weighed them against your rights and freedoms. You can ask us for that assessment.

You do not have to give us any personal data. We cannot reply to an enquiry without an email address, and the other questions on the form help us reply well.

Scoring enquiries

We give each enquiry a score from your answers, so the right person replies first. A person reads every enquiry. The score never decides whether we reply, and we make no decision about you by automated means alone that has a legal or similarly significant effect.

The contact form

The contact form has 3 steps. When you finish step 1 or step 2, we save what you have entered so far, even if you do not send the form. We do this so an enquiry is not lost when someone is interrupted.

We only save a work email address that passes our business email check. We may contact you once about an enquiry you did not finish. Tell us you would rather we did not, and we will delete it.

With the form we receive the page you sent it from. If you accepted advertising cookies, it also carries the page that brought you to the site and any campaign tags in that link. Enquiries are kept in Attio, our customer relationship management system.

The Sunday Close

The Sunday Close is our weekly email on AI in finance. We send it only to people who sign up, and every issue carries a link to unsubscribe.

We send it through Kit. Kit records whether each email is opened and which links are clicked, and we use those counts to see which topics readers find useful. By signing up, you agree to this measurement. It stops when you unsubscribe.

Analytics and advertising

Our cookie notice lists every tool, what it stores on your device and for how long. In short:

  • Google Analytics counts visits and shows us how the site is used. We set it up to report on the site as a whole. We do not use it to build profiles of individuals, and it does not share the data for advertising
  • the LinkedIn Insight Tag and Google Ads measure our advertising and show our adverts to people who have visited the site. They run only if you accept advertising cookies
  • Cloudflare Zaraz loads Google Ads only once you accept advertising. We load Google Analytics ourselves while statistics is on, and the LinkedIn Insight Tag only once you accept advertising

Google explains how it uses data from sites that use its services atpolicies.google.com/technologies/partner-sites.

LinkedIn

LinkedIn Ireland Unlimited Company uses Insight Tag data as a separate controller. Itsprivacy policyexplains how.

Who we share it with

We never sell personal data. We share it with the suppliers below, each for the work in the table. A processor acts only on our instructions under a contract. A separate controller decides for itself how it uses the data, under its own privacy policy.

SupplierWhat it does for usRoleWhere
Cloudflare, Inc.Hosts the site, protects it, runs the contact form and loads Google Ads through ZarazProcessorWorldwide network, US
Google Ireland LimitedGoogle AnalyticsProcessorEEA, US
Google Ireland LimitedGoogle AdsSeparate controllerEEA, US
LinkedIn Ireland Unlimited CompanyLinkedIn Insight TagSeparate controllerIreland, US
Attio LtdCustomer relationship managementProcessorIreland
Kit, Inc.Sends The Sunday CloseProcessorUS
Google LLCPlays YouTube videos when you press playSeparate controllerUS
Luma Labs, Inc.Runs registration for our eventsSeparate controllerUS

We may also share data with our professional advisers, with a buyer if the business is ever sold, and with the police, a regulator or a court where the law requires it.

Transfers outside the UK

Some of these suppliers process data outside the UK. UK law treats the EEA as giving adequate protection, so no further safeguard is needed there.

For the US, we rely on the UK Extension to the EU-US Data Privacy Framework where the supplier is certified. Otherwise we rely on the Information Commissioner's International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses. You can ask us for a copy of the safeguard that applies.

How long we keep it

We keep personal data only for as long as we need it for the purpose we collected it for.

DataHow long
An enquiry that does not lead to work2 years from your last contact with us
An enquiry you did not finish90 days
Records of work we do for a client6 years after the work ends, to meet tax and legal duties
The Sunday CloseUntil you unsubscribe. We then keep your email address on a list of people not to email, so we do not add you again by mistake
Site statistics14 months
Security logsAs long as Cloudflare keeps them for security, which is days, not months

Your rights

You have the right to:

  • ask for a copy of the personal data we hold about you
  • ask us to correct data that is wrong or incomplete
  • ask us to delete your data
  • ask us to restrict how we use it
  • object to our using it on the basis of legitimate interests
  • ask for data you gave us in a format you can take elsewhere
  • withdraw your consent at any time, where we rely on it

Email info@constancia.io to use any of these. We may ask you to confirm who you are. We reply within 1 month, or tell you within that month if we need longer, and why.

Direct marketing

You can object at any time to our using your data for direct marketing, including The Sunday Close. Tell us, or use the unsubscribe link in any email, and we will stop.

Complaints

If you are unhappy with how we have used your data, please tell us first at info@constancia.io. We acknowledge every complaint within 30 days, look into it, keep you updated and tell you the outcome.

You can also complain to the Information Commissioner's Office at any time:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone 0303 123 1113
ico.org.uk/make-a-complaint

Keeping it secure

We use suppliers with strong security, limit access to the people who need it and send data only over encrypted connections. If a breach puts your rights at risk, we will tell you and the Information Commissioner's Office as the law requires.

Changes to this notice

We update this notice when what we do with personal data changes. The date at the top shows when it last changed. If a change affects you in a way you would not expect, we will tell you before it takes effect.