Encompass Corporation Privacy Policy

This is the privacy policy of Encompass Corporation Group Holdings Limited Company (registration number 12535966), whose registered office is at Level 2, 60 Ludgate Hill, London, United Kingdom, EC4M 7AW, telephone +44 (0) 333 772 0002, and e-mail info@encompasscorporation.com.

Our Privacy Compliance Officer can be contacted using the information set out in the section Contact Information and Complaints.

Our business consists in making available a platform which aggregates data from a multitude of public and private sources which our customers use to comply with their anti-money laundering and counter-terrorism financing policies. We set out below important information about our processing of data relating to living individuals by reference to the purposes for which we do so in the context of our business.

Our privacy commitment

Encompass Corporation UK Limited is committed to managing your personal information openly and transparently and to keeping your personal information safe. We have published this policy with the view to foster trust in our processes, so that the people with whom we deal understand (as far as possible) what we do and why, in relation to personal data about them, and in order that, if you wish to challenge them, you have information about your rights. We provide additional information where appropriate in the circumstances, but this policy contains as much information as we can make available without reference to particular circumstances.

The Purposes for which we process personal information

The purposes are as follows:

• Marketing our business
• Entering into contracts without customers, partners and suppliers
• Making available our platform and performing our services
• Connecting our platform to sources of data
• Keeping records and accounts
• Operating our business
• Operating our website and use of cookies
• To enhance user experience on our website

We have included sections dedicated to describing your rights as an individual, our contact information, and how you can make a complaint.

Marketing

The basis on which we process data

We take pride in our business which thrives because we have a first-class platform and provide services of the highest quality. The market in which we operate is competitive and we must continue to expand. To that end we have a legitimate interest in marketing our platform and services. This involves using secure software to analyze user behaviours on our website to further enhance and improve our services.

The steps we take to attract customers bring us into contact with them directly and indirectly to communicate information about our platform and services. We are not intrusive and always respect the wishes of individuals once we are aware of them.

Types of personal data

We process the following classes of personal data in connection with our marketing:

• Contact details, including home and business address, telephone numbers, e-mail, and social media contact information, including on Linked-In
• Position and role within the organization

We use this data in order to:

• Communicate with people via telephone, e-mail, SMS text and other forms of electronic communication
• Send people materials about our business, events and developments relating to anti-money laundering and counter-terrorism financing law and practice

Types of personal data

We process data on the following classes of individual in connection with our direct marketing activities:

• Current customers
• Past customers with whom we wish to re-establish a relationship (unless we are instructed not to do so by them)
• Prospective customers
• Users who register on our website

How long we keep personal data

We keep all past and present information about our customers for marketing purposes, including a user’s preference or otherwise of being contacted, until we are no longer permitted to do so under applicable law, for example, where an individual objects to our holding of personal data relating to them for marketing purposes.

Connecting our platform to sources of data

We conduct our own market research of public sources of information, notably, company websites, directories of professionals, and social media, including LinkedIn. When we attend or hold events we use the information contained in the delegate lists that are provided to us by the event organizers and which, in the case of our own event, we prepare in respect of the invitees and in respect of the actual attendees.

We also obtain information from the individual in question about themselves and whether or not they are interested in receiving more information about our platform and the services.

We occasionally acquire lists of contacts who may be interested in our services from third parties.

Disclosures of personal data

We disclose personal information from time to time in the course of our marketing activities to the following recipients:

• Other professionals or prospective customers, subject to our duties of confidentiality (if any) to the contrary
• Marketing consultants providing services to us in connection with the development of our business, including the development of marketing campaigns

Entering into contracts with our Customers, Partners and Suppliers

The basis on which we process data

In the course of recording you as one of our customers, we process personal data in order to take steps at your request (acting for yourself or the organization you represent) prior to entering into our customer services agreement.

Types of personal data

We process the following classes of personal data in connection with engaging you or the organization you represent as a customer:

• Your name, title, date of birth, address, and contact details
• Details of a bank account over which you have authority on your own behalf or on behalf of our customer

Connecting our platform to sources of data

We will always collect personal information directly from the individual unless it is impracticable to do so. This will usually be done through application forms, order forms, over the telephone, in person or over the internet.

Disclosures of personal data

We don’t disclose to anyone any of the information we obtain for this purpose except subsequently in the course of making available our platform and providing our services.

How long we keep personal data

We keep all information about our customers and people associated with our customers for as long we need to do so to make available our platform and provide the services in accordance with our customer services contract, and afterwards in accordance with our policy on record keeping and accounts (see Keeping Records and Accounts).

Making available our platform and performing our services

The basis on which we process data

Once you or the organization you represent have entered into a contract with us, we are able to provide you with access to our platform and to provide our services. Naturally, it is also in our own legitimate interests to make available our platform and provide our services.

Types of personal data

The nature of any additional information we need to make available our platform and perform our services depends on our customer’s requirements. We obtain the information we need through the forms we ask them to fill in, and questions we ask, or when meeting them or others in person or speaking on the telephone. However, we won’t collect information for which we don’t have a reasonable need.

Connecting our platform to sources of data

• The individual themselves
• Colleagues of the individual
• People associated with you or our customers, including a partner, member, director or member of staff, suppliers and clients

Disclosures of personal data

Other than in connection with the Operation Of Our Business we don’t disclose your information to any third party in connection with making available our platform or providing our services, except where you or your organization are also a customer of one of our data providers and our platform is the means by which you are obtaining their data. In those circumstances, we may need to disclose information about you or your organization in accordance with our contract with the data provider.

How long we keep personal data

We keep all information about our customers and people associated with our customers for as long we need to do so to make available our platform and provide the services in accordance with our customer services contract, and afterwards in accordance with our policy on record keeping and accounts (see Keeping records and accounts).

Operating our website and use of cookies

Your personal information will not be collected if you are only browsing one of our websites but we do use cookies to better tailor our information and our services to meet your needs.

A cookie is a small piece of text that is placed within the memory of a computer and can be later retrieved by web page servers. Cookies are used to enhance your interaction and convenience in using our website and we do not use cookies to record any of your personal information. Cookies may record information about your visit, including the type of browser and operating system you use, the previous site you visited, your server’s IP address, the pages you access and the information downloaded by you.

While this anonymous statistical data may be aggregated and used in broader statistical analysis by us and our web monitoring service provider to improve our services, we cannot personally identify you as the source of that data until such point as you provide your personal information to us.

To find out more information on what cookies we use and the purpose of these cookies, please see our Cookie Policy.

Rights of data subjects

Individuals have several rights under EU data protection law in relation to how we process personal data relating to them. These are identified below so far as relevant to the basis on which we process personal data. More information can be obtained from the Information Commissioner’s website.

We cannot charge for providing an individual with information when he or she exercises their rights, except that we may charge a reasonable fee based on our administrative costs to provide additional copies where requested in connection with a request to access data, or where we can demonstrate that a request(s) is or are manifestly unfounded or excessive. In the latter case, we may alternatively refuse to act on your request.

Transparency of processing

A person has the right to receive information on what personal information we have, why and who we share it with.

Right of access

A person is entitled to have confirmed whether we process personal data relating to them, and if so, what personal data we process and to be provided with access to the information, subject to the need to protect the interests of others as appropriate. If you wish to receive a copy of the personal information we hold on you, you may make a subject access request.

Rectification

If personal data are inaccurate or incomplete, the data subject can require that they are corrected.

Right to restrict processing

Data subjects may require that their information be deleted or removed if there is not a compelling reason for us to hold it.

Right to data portability

A copy of personal data can be requested by the data subject for his or her own purposes to use across different services. In certain circumstances, he or she may move, copy or transfer the personal information we hold to another company.

Communication of a personal data breach

Where we are subject to a breach of security which is likely to result in a high risk to individuals about whom we hold data we must communicate the breach to the individuals concerned without undue delay. In some cases, this may be done by public communications. This right is subject to exceptions where measures have been taken to protect the information.

Right to object or withdraw consent

You can object to encompass processing your personal data where it is based on our legitimate interests, in which case we can no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

You can object at any time to our use of personal data relating to you in connection with our direct marketing. Where you do so, the personal data shall not afterwards be processed for such purposes.

Where we are processing personal data about you with your consent you can withdraw it at any time.

Contact information and complaints

Contact Details

If you have any questions about this Privacy Policy, the personal data we obtain and process about you, or any other privacy-related concerns, please don’t hesitate to contact us at:
Encompass Corporation Group Holdings Limited Company
Level 2, 60 Ludgate Hill, London, United Kingdom, EC4M 7AW
For the attention of: Privacy Compliance Officer

E-mail: info@encompasscorporation.com

We will use our best endeavours to address any such concerns thoroughly and in a timely manner. If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.

Changes to this policy

From time to time it may be necessary for us to review and revise this privacy policy. We reserve the right to change our privacy policy at any time.

Complaints

If we are unable to resolve your complaint to your satisfaction, you could refer the matter to the Information Commissioner’s Office. You can contact the ICO, who may even be able to bring your claim to the courts.