This policy was last updated on: 24th April 2018
Who are we?
Palantir Ventures Limited (“Palantir”) is a business consultancy company registered in England and Wales under company number 06705423. Our registered office is at 20 – 22 Wenlock Road, London, N1 7GU.
- Email to Justin Speake, our Data Protection Officer, at firstname.lastname@example.org;
- Using the contact form on our website;
- Writing to us at the registered address above; or
- Telephone on +44 (0)20 3397 7880.
Why do we need your personal data?
When we provide our Products and Services to you we will need to collect and use certain information in order to be able to provide those Products and Services efficiently and effectively. That information may include your personal data, but we will ensure that we only collect what is necessary for the purpose of delivering that Product or Service.
We do not use your information in any automated individual decision making processes, including profiling. Please do not use or register on our website for any of our Products and Services if you are under the age of 16.
What information will we collect about you and what is it used for?
We will collect the following information about you for the purpose of providing each of these Products and Services to you:
- If you place an order with us for our Products or Services, including downloading materials via our website, we may collect contact information (such name, job title, email address, phone number and geographical location) and payment information (such as credit or debit card information). Our legal basis for doing so is for completing our contractual obligations to you and for our legitimate interests in properly providing the relevant Product or Service to you;
- If you register as a member on our website we may collect your contact information (name, job title, email address, geographical location and IP address) so that you can contribute to discussions on blog posts on our website, and you can delete your account and all information submitted at any time by selecting that option on our website. We also perform checks on the information submitted for security and vetting purposes (which might include sending you an email asking you to confirm your details), to make sure that the registration has not been made by a bot or similar, or someone purporting to be you. Our legal basis for doing so is for our legitimate interests in the proper administration and security of our website and business, and communications with users;
- Where we conduct any survey, the survey will detail what information is being collected, the purpose it will be used for, the retention period of the data and the legal basis applicable to the data;
- If you use the contact form on our website we will collect personal data such as name, email address, phone number, job title, IP address and geographical location for the purpose of contacting you by email and/or phone to respond to you. Our legal basis for collecting this information is for our legitimate interests in the proper administration of our website and business, and communications with users;
- If you hand us your business card (for example, at a trade show) we will store your contact details in our electronic database and (unless you specified a different purpose, in which case they will be used for that purpose only) we may add them to our mailing list and use them to contact you about our Products and Services unless you tell us otherwise. Our legal basis for doing so is for our legitimate interests in resuming business communications with you;
- Some of our website Products and Services allow you to sign in using a single-sign-on service from a third party social media account. If you choose to use these single-sign-on services, you are granting permission to the relevant third party social media provider to share certain profile information with us, including your name, email details, address (including geographical location), and contact information, and we use this information as described in the relevant Service. For example, our IdeaPool Service allows you to log in and register your idea using your LinkedIn account. Where you choose to register your idea using the LinkedIn sign-on, LinkedIn shares your name, photo, location, email address, your short LinkedIn profile (200 words) and your LinkedIn url with us. This information is stored in our IdeaPool system along with your IP address and details of your idea. The details of your idea are published on our website against your profile, and you are able to delete your profile and idea at any time. We use the personal data from LinkedIn for the purpose of communicating with you in relation to your idea under the IdeaPool Service and we also use this information along with your IP address to verify your identity. Our legal basis for doing so is for our legitimate interests in providing the IdeaPool Service, and to ensure the security of our systems.
- Where you share information using a social media sharing button on the website, the relevant social network will record that you have done this. We have no control over that activity and it is governed by those companies’ own privacy policies;
- Where we have the appropriate permissions, we will use your information to market and advertise our Products and Services and those of our group companies to you by contacting you by phone and/or email using the contact information you have provided. You may also be contacted directly by our group companies for these purposes as further detailed below. Our legal basis for collecting this information will be that we have your consent for this purpose and you will be able to withdraw your consent at any time by clicking the link to unsubscribe in the relevant email, advising the caller or contacting us using any of the methods above.
Except where you have ordered or have entered into a separate contract with us to provide our Products and Services, you are under no legal or contractual obligation to provide your personal data to us and it is entirely at your discretion. However, if you choose not to we may be unable to provide the relevant Product or Service to you.
Will we share the information with anyone else?
- To our group companies and independent contractors: We may disclose your information to our group companies and individuals who are our independent contractors that need to know the information in order to help us provide our Products and Services to you (including as may be detailed in the previous section), or to process the information on our behalf.
- To our third party suppliers: We may share your information with our third party suppliers who need to know the information in order to provide their services to us. This includes our suppliers who help us provide our Products and Services to you or who administer our back office operations including our payment providers who process your credit and debit card information for us, our cloud-based business operations providers (such as accounts, hosting services, cloud storage, marketing and email providers, survey provider, SaaS and VOIP), our professional advisors (such as our accountants and lawyers) and those suppliers that help us to understand and enhance our Products and Services.
- As required by law: We may be required to disclose your information to comply with a legal obligation, under a court order, or other statutory or governmental request.
- Business transfers: We may disclose your information to a third party in connection with any merger, acquisition, sale of company assets.
- With your consent: We may share and disclose your information with your consent (for example, where you utilise social media services to connect to your account).
Where we disclose your information as detailed above to a third country (outside of the European Economic Area) or international organisation, we will only do so where appropriate safeguards are in place, as determined by the European Commission. Further details can be obtained by contacting the Data Protection Officer.
How long with you keep my personal data for?
Your personal data will not be kept for longer than is necessary for the purpose or purposes for which it was collected. When we collect the personal data we will normally advise you of the purpose it will be used for (unless otherwise covered above), and the period that the information will be retained for. However, in some cases it is not possible to advise you of the retention period in advance. In these cases we will determine the retention period based on the purpose that the information was obtained for, our legal obligations, and our technical and business requirements. We operate a data retention process to ensure that personal data is regularly reviewed for compliance with these retention periods.
You can unsubscribe from any or all of our mailing lists at any time by using the “Unsubscribe” option in the relevant communication, or by contacting us using any of the contact methods above.
What are my rights
As a data subject, you have certain rights with respect to the personal data that you have provided to us:
- The right to request a copy of the information that we hold about you;
- The right to request that we correct any personal data that we hold about you which is inaccurate or incomplete;
- In specific circumstances you can ask for the personal data that we hold to be deleted;
- Where specific conditions apply, the right to restrict the processing of your personal data;
- The right of data portability when transferring your personal data to another organisation;
- The right to object to certain types of processing (including automated processing);
- The right to complain to the Supervisory Authority (which in the UK is the Information Commissioner’s Office) as detailed below.
Further details of your rights can be obtained by visiting the Information Commissioner’s website.
Where you make a request based on the above, any third parties involved in the processing of your personal data may be informed of those requests.
If you wish to exercise any of your data subject rights, please contact us using the details above.
Cookies are very small text files that contain an identifier that is sent by a web server to a web browser and are stored by the browser on your computer. They are commonly used to retain settings or other features ready for your next visit. Cookies do not usually contain any information that would personally identify you, but they may be linked to the information that we store about you.
Cookies we use
When someone visits our website we collect standard internet log information and details of visitor behaviour patterns so that we can find out things like the number of visitors to the various parts of the website.
We will not associate any data gathered from our website with any personally identifying information from any source. If we do want to collect personally identifiable information through our web site, we will make it clear when we collect it and will explain what we intend to do with it.
These are all the cookies set on our website. Not all cookies are set by default, it depends how you interact with our site:
First Party Cookies
|PHPSESSID||Strictly necessary||Until you close your browser||To maintain information about each visit to the website and enable core site functionality. This cookie does not contain any personal information and only lasts for the duration of your visit.|
|wordpress_test_cookie||Strictly necessary||Until you close your browser||A test performed to see if cookies are enabled on your browser.|
|wordpress_*||Functionality||12 months||Used to maintain any user’s identity if they log into the site.|
|wordpress_logged_in_*||Functionality||12 months||Used to maintain any user’s identity if they log into the site.|
|wordpress_sec_*||Functionality||Until you close your browser||Used to maintain any user’s identity if they log into the site.|
|comment_author, comment_author_email, comment_author_url||Functionality||2 weeks||Cookies beginning with “comment_author_…” are only stored if you make a comment on the site. They store your name, email and website so you don’t need to re-input each time you make a comment on the site.|
|cookie_notice_accepted||Functionality||12 Months||Records that you have seen and actioned our cookie banner.|
Third Party Cookies
|linkedin_oauth_*||Functionality||Until you close your browser||Set by the social login system whether you use LinkedIn or not.|
|_ga||Analytical||2 years||We use Google Analytics software to collect information about how you use our website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements. We have opted to anonymise any IP information and not to share our analytics data with anyone.Google Analytics stores information about:|
|_gat||Analytical||10 minutes||Google Analytics cookie – see above (used to throttle request rate)|
|_gid||Analytical||24 hours||Google Analytics cookie – see above (used to distinguish users)|
You can decide if you want to accept or reject cookies by changing the settings on your browser.
How we will protect information about you
We do our utmost to protect your privacy. We do so by taking appropriate technical and organisational measures to protect your personal data to ensure that it is collected, processed and retained in accordance with our own high standards and our legal obligations. We have implemented industry-standard security systems and procedures to protect your information from unauthorised disclosure, loss, misuse or destruction. However, where you submit your personal data for publication via our website or a Product or Service you acknowledge that this information will be available via the internet, worldwide. We will delete any comments that you publish on our website (such as in response to a blog) upon your request to the Data Protection Officer, but bear in mind that we cannot control or prevent the use or misuse of this information by others, including where they replicate this information to other sites.
If you wish to complain about how Palantir processes your personal data, or how a personal data complaint has been managed, you can complain directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/.