Privacy Policy

Strategia Advisory respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website or otherwise.

 

Please read this Privacy Policy carefully.

 

  1. Definitions
    • In this Privacy Policy, the following definitions are used:

Data: collectively all personal information that you submit to us. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation.

GDPR: has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.

 

  1. Our Identity
    • Depending on the service provided, STRATEGIA ADVISORY LTD (collectively referred to as “we”, “us” or “our” in this privacy policy) may act as a data processor, a joint data controller or a data controller in our own right to manage and improve the service.
    • If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: STRATEGIA ADVISORY LTD

Email address: info@strategia-advisory.com

Postal address: Canada Tower 1 Canada Square, Level 39, London, England, E14 5AB

  • You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

  1. Changes to this policy
    • We keep our privacy policy under regular review.
    • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

  1. Changes to our business
    • We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will be permitted to use the Data for the purposes for which it was originally supplied to us.
    • We may also disclose Data to a prospective purchaser of our business or any part of it.
    • In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

  1. The Data we collect
    • We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      • Identity Data includes first name, last name and job title.
      • Contact Data includes billing address, delivery address, email address and telephone numbers.
      • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
      • Technical Data includes internet protocol (IP) address, your login data, browser type and version, type of device used.
      • Profile Data includes your username and password, purchases or orders made by you, communication preferences, feedback and survey responses.
      • Usage Data includes information about how you use our website, products and services.
      • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preference.
    • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
    • We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

 

  1. How we collect the Data
    • We use different methods to collect data from and about you including through:
      • Direct interactions. You may give us your Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you; or
    • give us feedback or contact us.
      • Automated technologies or interactions. As you interact with our website(s), we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
      • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

 

  1. How we use the Data
    • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • Where we need to perform the contract, we are about to enter into or have entered into with you.
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      • Where we need to comply with a legal obligation.
    • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

  1. Marketing
    • We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
    • You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
    • We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
    • You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

 

  1. Who we share the Data with
    • We may share your Data with the following groups of people for the following reasons:
      • any of our group companies or affiliates – to ensure the proper administration of our application and business;
      • our employees, agents and/or professional advisors – to be able to provide information on our products and services and to support our user community;
      • service providers acting as processors who provide IT and system administration services.
    • We will ensure that your personal information is not disclosed to unauthorised third parties, including family members, friends, government bodies, and in certain circumstances, the Police.
    • We may, from time to time, provide links to other applications. We have no control over such applications and are not responsible for the content of these applications. This Privacy Policy does not extend to your use of such applications. You are advised to read the Privacy Policy or statement of other applications prior to using them.
    • We do not use cookies on our website(s).

 

  1. Data security
    • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    • If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@strategia-advisory.com.

 

  1. Data Retention
    • Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.
    • Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

 

  1. Your Rights
    • You have the following rights in relation to your Data:
      • Right to access– the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
      • Right to correct– the right to have your Data rectified if it is inaccurate or incomplete.
      • Right to erase– the right to request that we delete or remove your Data from our systems.
      • Right to restrict our use of your Data– the right to “block” us from using your Data or limit the way in which we can use it.
      • Right to data portability– the right to request that we move, copy or transfer your Data.
      • Right to object– the right to object to our use of your Data including where we use it for our legitimate interests.
    • To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@strategia-advisory.com.