Privacy Policy

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Welcome to Octopus Consulting and our website at www.octopusconsulting.co.uk. At Octopus Consulting, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and services and how it is used.

General Information 

a) What law applies?

Our use of your Personal Data is subject to both the UK’s Data Protection Act (“DPA”), and the EU's General Data Protection Regulation (the “GDPR”), and of course we process your Personal Data accordingly.

b) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

c) What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

d) Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Octopus Consulting Solutions Ltd of 49 Russell Road, London, SW19 1QN (“Octopus Consulting”, “we”, “us”, or “our”). 

If you have any questions about this policy or our data protection practices, please email us at info@octopusconsulting.co.uk, call +44(0)7707 639 807, or write to us at the above address.

e) What are the legal bases of processing?

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

● For the fulfilment of contractual obligations

o The purposes of the data processing are primarily based on the service we provide.

● Within the framework of our legitimate interests

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:

o Ensuring IT security and IT operations,

o Measures for business management and further development of our services,

o Defense against third-party claims and enforcement of own claims.

● Based on your consent

o Insofar as you have given us your consent to process personal data for certain purposes. 

Data we collect automatically

a) Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

b) Hosting 

The hosting service used by us for the purpose of operating our website is GoDaddy.com, LLC. In doing so GoDaddy, processes all data to be processed in connection with the operation of this website, including log files on our behalf. The legal bases for processing are our legitimate interests, the provision of contractual services and the conclusion of the contract for our services.

c) Use of cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). 

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”), and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies and do so when you visit our website for the first time through our Cookie Consent Management Tool. For further information on the Cookies we use, please refer to our Cookie Policy.

d) Cookie consent

Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

e) Google reCAPTCHA

We also use Google`s reCAPTCHA from Google LLC to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.

f) Vimeo Videos

We have integrated components from Vimeo, Inc. The integration requires that Vimeo can perceive the IP address of the user. The IP address is required in order to send the video content to the user's browser. If you click on a Vimeo component (video) on our website, your internet browser will be prompted by the component to download a corresponding representation of the component. In this way, YouTube knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.

Data we collect directly

a) Contacting us

You can contact us in various ways, and in addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

b) When using our services

We process the Personal Data involved in your use of our services in order to be able to provide our services. Accordingly, the processing of data is limited to the strict needs of allowing you to use our services and is solely based on your consent. The legal basis for providing your data is the fulfilment of our contractual obligations and your consent.

c) Registration and Account

As part of the registration process, users provide their Full Name, Email address Phone Number) and Password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.

d) Careers and Applications

If you apply for a role or job, we process the information we receive from you as part of the application process, e.g., through your letter of application, CV, references, correspondence, telephone, or verbal details. In addition to your contact details, information about your education, qualifications, work experience and skills is particularly relevant to us. 

Your data will initially be processed solely for the purpose of carrying out the application process. If your application is successful, it will become part of your personnel file and will be used to carry out and terminate your employment and will be deleted in accordance with the rules applicable to personnel files. If we are unable to offer you employment, we will continue to process your data for up to six months after sending the rejection in order to defend ourselves against any legal claims, in particular alleged discrimination in the application process. 

The legal basis for processing data during the application process is the initiation of a contract and, if you have given your consent, for example by sending us information that is not necessary for the application process. The legal basis for data processing after a rejection is our legitimate interest. 

e) Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

f) Data management and customer support

For optimal data management and customer support, we may store the data related to your use of our services with us in our Google Workspace. This data processing is based on our legitimate interest in providing our customer service.

g) Marketing 

If you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. The legal basis for processing is the initiation of a contract, our legitimate interest and your consent.

h) Social Media

We are present on social media and if you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.

General Principles

a) Who receives my data?

Within Octopus Consulting, those that need your data to fulfil our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data. 

b) How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods among others. The retention and documentation periods specified there are up to 6 years.

c) How do we secure your data? 

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. 

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

d) Is data transferred to a third country or to an international organisation?

We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your personal data may be transferred to countries outside the UK and the EU. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the personal data we transfer.

e) Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

f) Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

g) Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

h) Do Not Sell

We do not sell your Personal Data.

Your Rights and Privileges 

a) Privacy rights 

Under the DPA and GDPR, you can exercise the following rights:

● Right to information

● Right to rectification

● Right to object

● Right to deletion

● Right to data portability

● Right to withdraw consent

● Right to complain to a supervisory authority

● Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

b) Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. 

c) Withdrawing your consent 

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d) Access Request 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk 

Changes, Contact and Effective Date

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above. The effective date of this policy is Monday, 31st July, 2023.