Introduction

We value your privacy at Martello Expert Services, and we are committed to making it as easy and transparent for you to manage and understand how we use your data. In line with GDPR regulations concerning data protection, our privacy policy outlines how we collect, store and process your data. It also describes the choices available to you regarding our use of your personal information, and how you can access and update this information. If you have any questions, comments or complaints, or if you would like to request copies of your data, delete or opt out of all data services, please contact: info@martelloglobal.com.

When do we collect personal data?

• you use this website;
• ou enquire about, or engage Martello Expert Services to provide its services (either in a personal capacity, or as a representative for your employer or client);
• the use of your personal information is reasonably necessary to provide our services (in these circumstances,your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
• you apply for a position with Martello Expert Services;
• you attend a hosted or sponsored event; or
• you contact us with any other enquiry, complaint or notice.

What data do we collect?

Website Users

Our Site may use “cookies” to enhance visitor experience. Cookies are small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Former, Current and Prospective Clients

If you submit an enquiry to Martello Expert Services about our services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.

If you attend a Martello Expert Services event, or if you associate with a Martello Expert Services colleague at, for example, an industry event, then we may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as a client or prospective client.

If you or the organisation you are associated with becomes a Martello Expert Services client, then we may process your personal information to:

• carry out conflict checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
• carry out client communication, service, billing and administration;
• deal with client complaints; and
• administer claims.

Taking account of applicable marketing laws, we also process personal information about our clients (former, current, and prospective) in order to:

• send our clients newsletters, know-how, promotional material, and other marketing communications; and
• invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients

As discussed above, many of our services involve the processing of personal information. In most cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use/disclosure.

Other Uses

If you apply for a position with Martello Expert Services, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

If you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, or to resolve that enquiry.

What is our legal basis for collecting personal information?

All processing, i.e., use of your personal information, is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

• the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g., where you request certain services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
• the processing is necessary for us to comply with a relevant legal obligation (e.g., where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
• the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent to send you marketing communications.

Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

• your explicit consent;
• the establishment, exercise or defence by us or third parties of legal claims; or
• other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.