Privacy Policy and Cookies Policy 

Summary

We’re committed to protecting and respecting your privacy and we believe it should be easy for you to understand our data and privacy practices. We aim to explain in clear language what information we collect, how we use it, and the choices and controls you have.

1. Our commitment to privacy

This privacy policy (‘Privacy Policy’) sets out how Collingwood Advisory Limited (‘Collingwood Advisory’) (‘we’, ‘us’ and ‘our’ being interpreted accordingly) uses and protects the personal information about you that we collect or that you provide, including from the public domain, our previous interactions with you, through your use of our website(s) collingwood-advisory.com and crescent-scaleup.com (each a ‘Website’), when you become a member or client, participate in our programme(s) or communities, or when you sign up to receive marketing information or other company updates.

2. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

3. Information about you

3.1. We may collect and process personal information from you in various ways, for example if you:

• contact us by phone, email, online using a form on a Website, face-to-face or otherwise in writing;
• become a registered user of a Website;
• become a customer;
• register for a meetup or webinar;
• request further information about a service or product;
• fill out an online form for access to content or newsletters;
• register and/or purchase services or products from us;
• participate in our discussion boards on a Website or social media platform;
• enter a competition or prize draw;
• complete a survey;
• submit a job application;
• visit our Website (please see the ‘Cookies’ section below); 
• report a problem with a Website, event, product or service; 
• approve marketing to be sent to you;
• engage in conversation with us about our services;
• have been recommended to us by a prior or current customer;
• we contact you because you are a prospective customer; or,
• work for an organisation that is an existing, prior or prospective customer.

3.2. 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, title, username, email address or similar identifier, phone number, social media links, photo, CV, and other information about your qualifications, and your right to work, if you choose to provide such details.
• Work Data: includes job title, company details, email address, username or similar identifier, phone number, country/location, team size, job history, social media links, development goals, account management notes.
• Contact Data: includes billing address, delivery address, first names, last names, email address and telephone numbers.
• Financial Data: includes bank account or payment card details, billing name, billing address, billing email. 
• Transaction Data: includes details about payments to and from you and or your company, spend amount, 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, 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 this website.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, social media links, conversation contributions, account management notes.
• Usage Data: includes information and reporting about how you use our website, products and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and third parties and your communication preferences.

3.3. Such personal information is referred to in this Privacy Policy as ‘Personal Data.’

3.4. 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). Nor do we collect any information about criminal convictions and offences.

4. Information we receive from other sources

4.1. We work closely with third parties, for example, event venues, webinar providers, sub-contractors in payment and delivery services, advertising networks, analytics providers, search information providers, and may receive Personal Data about you from them.

4.2. We may record information about you that is available publicly from sources like LinkedIn, corporate websites, related industry websites and online directories. We may then research and record further details about you by contacting your company directly or searching online.

4.3. If you use a messaging, chat or discussion service on one of our Websites, we have access to those communications.

4.4. If you‘re applying for a job at Collingwood Advisory, we may receive information about you from your referees and former employers.

4.5. If you use our pages on social media platforms, then we may collect any Personal Data which you provide via those platforms in accordance with the policies of the applicable platform.

5. Personal Data about other people

If you provide Personal Data to us about any person other than yourself, such as your colleagues, personnel, relatives, your next of kin, your referees (if you are applying for a job), your clients, your advisers or your suppliers, you must ensure that they have given their permission for you to disclose it to us and for us to use it in accordance with this Privacy Policy.

6. Sensitive Personal Data

6.1. Unless we make it clear otherwise, our policy is not to ask for any sensitive Personal Data from you. 

6.2. If you choose to provide this sensitive Personal Data to us, this will mean that you have given your consent for us to use that information for the reasons explained at the time you provide that sensitive Personal Data to us.

7. Uses we make of Personal Data

7.1. We may use the Personal Data that you provide to us or that we receive from third parties in the following ways:

• Direct marketing purposes: where you have expressly consented to us doing so in accordance with applicable law, you have purchased services or products from us or we otherwise have a legitimate interest or legal right, we may contact you by telephone or electronic message (e.g. email, SMS or via a messaging app) for the purposes of providing information on our services and products, or providing information on behalf of our partners. We may also contact you by post from time to time, unless you have told us that you do not want to receive these communications. If you wish to update your Personal Data or opt-out of receiving further marketing communications from us email marketing@collingwood-advisory.com
• Transactional purposes: we may process your Personal Data to provide you with the information that you request from us, to carry out our obligations arising from any contracts entered into between you and us, including managing your registration, attendance and participation at an event, which may include transferring your information to other organisations (see section headed ‘Disclosing Personal Data to third parties’ below); to allow you to participate in interactive features of our Website and services when you choose to do so; to allow you to communicate with other users on our Website;
• Website administration and improvement: we may process your Personal Data to manage your access to Collingwood Advisory content and resources, and the access by authorised users within your organisation; to ensure that content from our Website is presented in the most effective manner for you and your computer or mobile device (see section headed ‘Cookies’); to notify you about changes to our events, products, services or Website(s); as part of our efforts to keep our Website safe and secure, and for troubleshooting;
• Marketing analysis and online marketing: to analyse Personal Data with a view to identifying how we can improve our marketing materials; provide you with products or services that can help to grow your business and send you marketing materials accordingly; to make suggestions and recommendations to you on our Website about services that may interest you (please see ‘Profiling’ and ‘Cookies’ sections below); to match the email we hold for you to your LinkedIn or Facebook account in order to target advertising to that account;
• Internal administration and analysis: to process your job application; to administer the Collingwood Advisory database; data analysis, research, statistical and survey analysis; to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• Legal compliance: to comply with any relevant legal obligations;

7.2. We may also contact you for other purposes that you consent to from time to time.

8. Profiling

8.1. Please note that we may occasionally use Personal Data to conduct profiling of individuals on our database. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of individuals receiving inappropriate or irrelevant communications. To do this profiling we:

8.1.1. may cross-check certain Personal Data against public sources (such as a company website) to get a better understanding of who the individuals on our database are; and

8.1.2. track your online behaviour in response to our emails and on our Website.

8.2. You can object to such use of your Personal Data for profiling at any time by emailing marketing@collingwood-advisory.com.

9. Legal obligations

9.1. We collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. This includes national laws implementing the EU Data Protection Directive (95/46/EC) and from 25 May 2018 the EU General Data Protection Regulation (2016/679), also referred to as “GDPR”.

9.2. For the purpose of the Data Protection Act 1998 (the ‘Act’), the data controller is Collingwood Advisory Limited whose company number is 05842662 and registered address is c/o Shelley Stock Hutter LLP, 16 Great Queen Street, London WC2B 5AH. 

10. Disclosing Personal Data to third parties

10.1. We never sell, trade or rent Personal Data.

10.2. We may disclose your Personal Data to the extent necessary to the following third parties:

• Third party service providers: if you are enquiring about, registering for, or purchasing products, services or events from us, we may disclose your information to third parties involved in their delivery and the provision of our online systems;
• Event partners or business partners: for information, please see ‘Uses we make of Personal Data’ section above.
• A purchaser of the business or business assets: if Collingwood Advisory, its business, or its assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets;
• Authorities, companies and advisors for legal reasons: we may disclose Personal Data to other companies and organisations for the purposes of crime prevention and fraud protection or if we are otherwise under a duty to disclose or share your Personal Data in order to comply with any legal obligation; or to protect the rights, property, or safety of Collingwood Advisory, our Website users, our customers, or others;
• Referees or employers: if you are enquiring about a job, or making an application, then we may disclose your Personal Data to third parties such as your referees, or current and previous employers (if you ask us to contact them).

10.3. We always aim to ensure that Personal Data we pass to third parties is used by them only for lawful purposes in accordance with this Privacy Policy.

11. Where we store your Personal Data

11.1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting personal data, you acknowledge that this transfer, storing or processing may occur.

11.2. We have also contracted with third party providers who may transfer your Personal Data outside the EEA:

• Hubspot, Inc. (‘Hubspot’): manages our customer relationship management (‘CRM’) database and provides our marketing automation platform, so your Personal Data may be hosted by Hubspot in the United States. For more information please visit – https://legal.hubspot.com/privacy-policy
• Xero: provides our accounting systems and may transfer Personal Data outside the EEA. For more information please visit – https://www.xero.com/uk/about/legal/privacy
• Zoom: provides our live webinar streaming and virtual video meeting services. For more information please visit – https://zoom.us/privacy and https://zoom.us/gdpr

11.3. You should be aware that, in general, legal protection for Personal Data under applicable law in the United States and other non EU countries may not be equivalent to the level of protection provided in the EU. However, in all cases, Personal Data will only be disclosed to third parties who are bound to treat Personal Data confidentially and in accordance with privacy standards that reflect this Privacy Policy and applicable law.

12. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us at marketing@collingwood-advisory.com.

We will retain certain Personal Data in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which in the UK may be up to six years after a particular transaction).

13. Cookies

Our Website uses cookies to distinguish you from other users of our Websites. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy below.

14. Security

We employ appropriate technical and organisational security measures to protect Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We also endeavour to take all reasonable steps to protect Personal Data from external threats. However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of all data disclosed or transmitted to us.

15. Links

Our Websites may, from time to time, contain links to and from the websites of our sponsors, media partners and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the processing of your data by those websites. Please check these policies before you submit any Personal Data to these websites.

16. Your rights

16.1. In accordance with your legal rights under applicable law, you can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to.

16.2. You can also request that we:

• correct Personal Data that we hold about you which is inaccurate or incomplete;
• erase your Personal Data without undue delay;
• no longer use your Personal Data for marketing purposes (please see the ‘Direct Marketing’ section above); or
• transfer your Personal Data to another organisation, for example, an alternative provider.

16.3. We may forward the above requests on to a third party provider who is involved in the processing of your Personal Data.

16.4. Please note that Collingwood Advisory is not required to rectify or erase your data where doing so would prevent you from meeting your contractual obligations to Collingwood Advisory or where Collingwood Advisory is legally required to retain copies of your Personal Data.

16.5. If you would like to exercise any of the rights set out above, please email marketing@collingwood-advisory.com. Where applicable law allows, we may request a fee to cover our administrative expenses in responding and may also require further information to verify your identity or locate the specific information you seek before we can respond in full.

16.6. If you are not satisfied with our response or believe we are processing your Personal Data other than in accordance with applicable law, you can complain to the Information Commissioner’s Office (ICO) in the United Kingdom.

17. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be sent to marketing@collingwood-advisory.com or by post at Collingwood Advisory Limited, c/o Shelley Stock Hutter LLP, 16 Great Queen Street, London WC2B 5AH.

Cookie Policy

What are cookies?

Our website uses cookies. A cookie is a small text file which is stored on your computer, tablet or phone when you visit a website. These cookies allow us to distinguish you from other users of our website. This helps us to provide you with a more personalised experience when you browse our website, allows us to monitor website use and helps us identify how we can improve our website.

There are two main types of cookie:

• session cookies – these are deleted when you finish browsing a website and are not stored on your computer longer than this
• persistent cookies – these are stored on your computer after you have finished using a website so that the website provider can remember your preferences the next time you use it

Cookies can be set by the website you have browsed, i.e. the website displayed in the uniform resource locator (URL) window. These are called first party cookies. Third party cookies are set by a website other than the one you are browsing.

2. Why do we use cookies?

We use cookies to collect the following information:

• Technical information including the internet protocol (IP) address used to connect your computer to the internet; your site login information; the browser and version of the browser that you are using, the time zone setting, browser plug-in types and versions; your operating system.
• Information about your visit to our website including the websites you visited before and after ours; products, services or other terms you searched for; page response times, download errors, length of visits to certain pages; page interaction information (such as scrolling, clicks, mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

3. Consent

If you continue to use our website we will assume that you are happy to receive all cookies from our website. However, if you would prefer to change your cookie settings, you can do so at any time—see below ‘Controlling our use of cookies’.

4. Controlling our use of cookies

Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by any websites, you can generally do this through your browser settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser.

If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our site.

If you delete cookies relating to this website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit the site.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.aboutcookies.org.uk/.

5. Queries

If you have any questions or comments regarding this Cookies Policy, please email marketing@collingwood-advisory.com.