Introduction
Your privacy is important to us and we want you to understand how QuoLux Limited (“QuoLux™”) handles personal information. QuoLux™ is committed to safeguarding the privacy of our users while providing a personalised and useful service. This statement on Privacy explains the data processing practices of QuoLux™ and applies to personal information which we process in the course of doing business including information processed through our website and the services that we provide.
If you have any requests concerning your personal information, or any queries on these practices, please contact us by post or e-mail (see Contacting QuoLux™ below).
QuoLux™ may change this policy from time to time. This policy was last updated on 1st August 2023.
About Us
We are QuoLux Limited a company registered in England and Wales (Company No. 06543734) with its registered office at B9 Elmbridge Court, Cheltenham Road East, Gloucester, Gloucestershire, GL3 1JZ, United Kingdom.
We are UK based company which markets its services and programmes in countries around the world, so when you provide us personal data, that data may be used, processed, or stored anywhere in the world, including in countries that have data protection laws that are different to the country in which you reside. However, QuoLux™ has policies and procedures in place that are constructed to safeguard and ensure an equal level of protection is applied across the entire organization and in accordance with this Policy.
QuoLux™ has an international division based in Brazil with staff who process and store personal information where required. For further information, please see ‘Security’ below.
Data Protection Principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
a) processed lawfully, fairly and in a transparent manner,
b) processed for specified, explicit and legitimate purposes,
c) adequate, relevant and limited to what is necessary,
d) accurate and kept up to date,
e) kept for no longer than necessary, and
f) processed in a manner that ensures appropriate security
Personal Information collected/held
We may collect, use, store and transfer different kinds of personal information about you, including:
a) Identity data, such as your name, marital status, title, date of birth, gender, job title and your employer
b) Contact data, such as your home and work addresses, personal and work email addresses and personal and work telephone numbers
c) Medical data, including details of any medical conditions,
d) Third Party data, including identity data and contact data relating to your family members, business colleagues and other contacts
e) Financial data, such as your bank account and payment card details
f) Transaction data, including details about payments to and from you, and other details of services you purchase from us
g) Technical data, including IP addresses, your log in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
h) Profile data, such as your username, password, your preferences, feedback and survey responses
i) Usage data, including information about how you use our website, products and services, and
j) Marketing data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences
How we collect your personal information
We may obtain personal information:
a) When we meet with you in our office or elsewhere
b) When you correspond with us by phone, email, letters or otherwise
c) When you fill in forms on our website
d) If you participate in discussion boards or other social media functions on our website
e) If you give us your business card
f) When you subscribe to our services or publications, or otherwise requesting marketing material to be sent to you, or
g) We may also obtain information automatically about you via automated technology when you visit our website by using cookies, server logs and other similar technologies
How we use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
a) you have given us consent
b) we need to perform a contract we are about to enter into, or have entered into with you,
c) where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interest, or
d) where we need to comply with a legal or regulatory obligation
Purposes for which we will use your personal information
We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information when we enter into a contract with you (to provide a service to you or for you to provide a service to us).
It will be necessary for the performance of the contract between you and us to collect and recover money owed to us.
It will be necessary for our legitimate business interests, namely to ensure we receive payment for services that we have provided to notify you about changes to our terms of business or this privacy policy.
It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to and recommendations to you and other users of our website about goods or services that may be of interest to you or them be of interest you or them.
It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website. We will comply with our cookie policy when processing this information to provide you with information about special offers and other services we provide that are similar to those that you have already received from us.
Where you have previously received marketing communications from us then it will be necessary for our legitimate business interests to ensure you continue to receive communications that you have previously agreed to receive.
It may be in our legitimate business interests to send you email marketing. For the purposes of email marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
It will be necessary for our legitimate business interests to ensure you are aware of the latest developments in relation to the services we have provided to you, or are providing to you, or otherwise to develop our relationship with you.
We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place sensible physical, electronic and managerial procedures to safeguard and secure the information we collect including:
a) Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
b) Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
c) Our internal policies require that users lock or log-off from their devices when they are unattended.
d) Electronic access. All data stored electronically is password-protected. Where we have provided an authorised user with a password, that user is responsible for keeping this password confidential and is not permitted to share the password with anyone.
e) If you are a delegate on one of our programs, you should be aware that some items of your personal information may be visible to other delegates via our online Communities or in the QuoLux™ Leadership Centre, which can only be accessed by delegates and alumni who are provided with a secure password. On the QuoLux™ Communities and Leadership Centre we may hold personal information including your name, e-mail address, and company details. That data will be generally visible to other delegates and alumni who can only access the Community and / or Leadership Centre by using their allocated password.
f) If you have a username and password for any of the features on our websites, you are responsible for keeping your password secret. You should not reveal your password to anyone. You should take reasonable precautions when using a computer that is not your own or in a public setting.
QuoLux™ makes every effort to protect personal information by users of the web site, including using firewalls and other security measures on its servers. No server, however, is 100% secure, and you should take this into account when submitting personal or confidential information about yourself on any web site, including this one. Much of the personal information is used in conjunction with member services such as collaboration and discussion, so some types of personal information such as your name, company affiliation, and email address will be visible to other Forum members. QuoLux™ assumes no liability for the interception, alteration, or misuse of the information you provide. You alone are responsible for maintaining the secrecy of your personal information.
If your information is provided to us as part of an event that we host in partnership with a third party, we may share your information with that third party and it will then be subject to the terms and conditions of their privacy policies.
Data may also be supplied to agents of QuoLux™ who provide services for QuoLux™. QuoLux™ will obtain assurances from its agents that they will safeguard personal information in a manner consistent with this privacy policy.
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the United Kingdom (UK). For example, some of the data that we collect from you may be transferred to and stored in Brazil. It may also be processed by personnel operating in Brazil who work for us. By submitting your personal data, you agree to this transfer, storing or processing. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the UK in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the UK, your information may be transferred outside the UK in order to provide you with those services.
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in the UK and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
Use of Website Cookies
When someone visits the Website, our servers automatically gather information that allows the site to communicate with the visitor’s computer during the visit. We also track the number of visits to the site and which parts of the site visitors select. We use those types of information for statistical purposes to help us administer and improve the site. Those types of information do not disclose personal information that would permit us to identify or locate individual visitors.
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information back from the browser. We use “cookies” to identify you when you visit the Website. This enables us to build up a demographic profile of visitors to the site.
If you don’t want cookies to be stored on your device, you should make the necessary changes to your device or the relevant browsers or apps.
This website uses Google Analytics tracking software to monitor you to better understand how you use it. This software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.
Disclosures
We will not disclose any information we keep about you to any third parties, except for other companies that QuoLux™ own in part and any suppliers we engage to provide services which involve processing data on our behalf.
Social Media Platforms
We participate with social media platforms subject to their privacy policies and terms.
You should use social media platforms wisely and communicate/engage upon them with due care and caution in regard to your own personal data. We will not request personal data through social media platforms. If you want to discuss something of a sensitive nature, then please use a more appropriate channel such as a telephone call or email.
This website may use social sharing buttons which help share web content directly from web pages to social media platforms. You should use these buttons with care. Note that the social media platform may track and save your request to share a web page through your social media platform account.
We share web links on social media pages. Sometimes, these links can be shortened. These shortened URLs or even the displayed URL can be hacked or otherwise changed against our wishes to divert you to another site. We are not responsible if you are redirected to the incorrect site.
Links to other websites
Our website may contain links to other websites of interest. However, you should note that we do not have any control over these other websites. Once you have used any of these links to leave our site, therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and such sites are not governed by this privacy statement.
How long we will store your personal information
We retain information for as long as we reasonably require it for business or regulatory purposes. If you are a delegate on one of our programmes, we would usually retain personal information for 5 years after our ongoing working relationship with you ends.
Your legal rights
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
a) You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b) You have the right to object to stop using/storing your information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing. purposes. We will stop using/storing your information unless we can demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms.
c) You have the right to ask us to stop using your information where:
i. the information we hold is inaccurate;
ii. we are unlawfully using your information;
iii. we no longer need the information;
iv. we do not have a legitimate reason to use the information
d) You have the right to ask us to transfer your personal data to another person or company in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
e) You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
f) If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or by notifying us in writing, by email or by telephone.
g) You have the right to object to us using/storing your information for direct email marketing. You can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know in writing, by email or by telephone.
h) f you wish to exercise any of your legal rights, please contact us in writing, by email or by telephone.
i) If you are not satisfied with how we manage your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).
Identifying you as a client
If you are a business client, we may identify you as a client of the company in our marketing material or on our website, although we will never publicly disclose any confidential information about you or your company without having obtained your prior consent. If you do not agree to us identifying you as a client of the company, please notify us.
Children’s data
At QuoLux™, we do not market to children. Our websites are designed and intended for use by adults.
If we discover that we have collected personal data from a child without consent from a parent or guardian, we will delete that personal data as soon as practical.
Changes to our policy
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.
Contacting QuoLux™
If you have any questions, comments or complaints about this Privacy Policy, please contact us using the details below:
By post – QuoLux™ Ltd, B9 Elmbridge Court, Cheltenham Road East, Gloucester, Gloucestershire, GL3 1JZ, United Kingdom
By email - info@quolux.co.uk
By phone - +44 (0)1242 386880
