CONTACTS PRIVACY NOTICE

1.    Introduction

The Compass group of companies ("Compass", "we", “us” or "our") respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Privacy Notice explains how we collect, share and use personal information about our business contacts, and the rights you have in connection with that information.

If you have any questions or concerns about this Notice or about our use of your personal information, then please contact us using the email address given in Section 10 below.

2.    What personal information does Compass collect and why?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

We ask you to provide certain information voluntarily.  The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

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In addition we may correspond with you and that may contain certain personal data that we exchange in the ordinary course of business, such as to schedule meetings and calls.

If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including from other suppliers and business partners), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

3.    Who does Compass share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to other Compass companies, third party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;

  • to clients where we have entered into a contract with you for and on behalf of the client or we are in a joint venture with you and have a contract with the client; or

  • to any other person with your consent to the disclosure.

4.    Grounds for lawful processing personal information

Our grounds for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

Our legitimate interests in the context of the personal information we may collect which is described in this Privacy Notice, will be for the purpose of receiving services from our service providers, providing services to our clients or in the case of partners, for the purpose of the collaboration or partnership.

If we collect and use your personal information in reliance on anything other than our legitimate interests, we will make clear to you at the relevant time. For example, if we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the grounds on which we collect and use your personal information, please contact us using the email address given in Section 10 below.

5.    How does Compass keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

6.    International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country.

Specifically, other Compass Group companies and our third party service providers, clients and partners operate in countries worldwide.  This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

7.    Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to receive services from you or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8.    Your data protection rights

You may exercise the rights available to you under applicable data protection laws, which in the European Economic Area (“EEA”) are as follows (similar rights may be available in some countries outside of the EEA):

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the email address given in Section 10 below.                                                                                                                                                       

  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information by contacting us using the email address given in Section 10 below.

  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the email address given in Section 10 below.

  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

  • You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9.    Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the date at the top of this notice.

10. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us by sending an email to data.privacy@compass-group.com.