Data and privacy lie at the heart of what we do
Who we are
Threat Essentials Ltd, a limited company registered in England (company number: 12460661), whose registered office is c/o Work.Life, 33 Foley Street, London, W1W 7TL, United Kingdom.
Threat Essentials Ltd is the controller in respect of your personal data collected through our digital services.
Our full contact information can be found at www.threatessentials.com/contact.
What information do we collect and where do we get it from?
Personal data or personal information is any information about you from which you can be identified. It does not include data where your identity has been removed (this is called anonymous data).
We collect and process different kinds of personal information about you and use different methods to collect it, as follows:
Identity and contact information: this includes your full name, contact details, (including your email address and mobile phone number), job title, physical address and information about the company you work for;
- Technical and usage data: if you use our digital services, we collect certain information through automated technologies. The type of information we collect includes details of the device you use, traffic data, location data (including the country and telephone area code where your computer device is located, and other technology on the devices you use to access it, as well as information about how you use our digital services and the resources that you access (including the pages of our digital services that you view). We collect this personal data by using cookies, server logs and other similar technologies.
- Marketing and communications data: this includes your preferences in receiving marketing from us and your communication preferences.
- We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not take data search to individuals. 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 or any data relating to children.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by sending an email to email@example.com.
What is our legal basis for collecting and using your personal information?
We will only use your personal data when the law allows us to. Most commonly we will use your personal data where it is necessary for our legitimate interests. Our legitimate business interest is in conducting and managing our business to enable us to give you the best services, and to provide you with the best and most secure experience when using our digital services. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We also rely on public interest as our lawful basis. This is on the grounds that it is in the public interest that organisations, public authorities, and others can find smart ways to identify and remediate data breaches. This can be vital in terms of maintaining fair standards in the activity of business markets, protecting the business resources of commercial entities against theft and other abuse, just as encouraging the identification of personal data breaches and their quick rectification.
How do we share your personal information?
Personal information we collect as part of our threat intelligence software platform:
When you are interested in our services or when you buy our services and entering into a written agreement with us, we may use your personal information in the following ways:
- to carry out our obligations arising from any contracts entered into between you and us. For example, we will use your personal data to process and fulfil your requests for services.
- to provide, enhance and personalise your experience when using our digital services;
- to identify and prevent fraud and to assess creditworthiness;
- to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);
- in order to enforce or apply any contract we have with you (or which concerns you) such as our Digital Services T&Cs, Terms and Conditions of Sale, and Supply & Install Terms, and to protect our rights, property or safety or those of our customers, employees or other third parties; and
- to comply with any legal or regulatory obligation which is imposed on us.
When our advanced threat intelligence software platform picks up your personal information
We will be searching and collecting data from publicly available webpages and files (PDF files or Word or Microsoft office documents or any other file formats) on the internet and the dark web to scan for potential security risks that might impact our customers in a negative way. In doing this, we may run into your publicly available personal information. Supplying advanced threat intelligence services to our customers is our basis for proceeding like this, as we do not aim our efforts at collecting data regarding specific members of the public who have no ties to our customers.
We may collect any publicly available personal information about you on the dark web, or on the internet. For the most part, in the event we process any personal information about you, such information will incorporate the following: name, email address, contact details, social media accounts work and home address and aliases.
Personal information we collect in the normal course of business, excluding our threat intelligence software platform:
• When we are conducting Marketing campaigns:
We may use your personal information in the following ways:
• to carry out market research. For example, we may contact you (including by email) to obtain your feedback on our products and services, and we may use details of your purchases to understand market trends and to identify popular products;
• to help us review, develop and improve the products and services we offer, including our digital services, and to improve and develop our customer database;
• for internal business and data analysis;
• to ascertain the products and services that are likely to be of particular interest to you in order to send tailored marketing information to you. For instance, if you browse pages of our procurement services in relation to a particular category, we may use this information to send you marketing communications about that category of product.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if we have your personal information and you have not opted out of receiving them. You can indicate the specific types of marketing communications you are particularly interested in receiving from us, and we will tailor the communications you receive to reflect your choices. We may however also send you other communications that we think may be of interest to you, unless you opt out of receiving them.
You can change your preferences or ask us to stop contacting you with marketing information by any communication channel (telephone, email or post) at any time by following the opt-out links on any marketing message sent to you, or by emailing us at firstname.lastname@example.org. Please note that, even if you choose not to receive marketing information, we may still use your personal information to provide you with important services communications.
• When you are one of our suppliers:
Suppliers are understood as any third party that provides goods or services to us (such as a consultant, contractor, advisor or vendor). Board members under a non-employee status are also considered as suppliers.
The main reason we process your personal data is to approve or manage an agreement between us and the supplier you represent or work for. In order to do this, we may use your personal data to issue purchase orders, process payments, perform accounting, manage our contract or review the services or products you supply us with. In addition, we process personal data to meet our legal responsibilities (such as record keeping obligations, screening duties of board members), as well as to manage our risks and operations (e.g. prevent and detect security threats, exercise or defend legal claims).
The personal data we collect from you come from the following sources: personal data you give us as well as information we receive from other sources.
• When the purpose changes:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Who do we share your personal information with?
We may share your personal information with the following third parties:
- Companies and other persons who provide services to us. For example, we engage other companies to update our databases of customer details (including the removal of repetitive information), analyse data, help us develop, provide, and improve our digital services and provide us with marketing assistance. We also use IT subcontractors, hosting services and payroll providers (relevant to employee data only).
- Professional advisers (including lawyers, bankers, auditors, and insurers in the UK and overseas, who provide us with consultancy, banking, legal, insurance and accounting services);
- Government bodies, regulators, and other authorities in the UK and overseas, who require reporting of activities in certain circumstances (for example, HMRC, Office for National Statistics etc.);
- Other parties as we may be required to by law or regulation, including for the purpose of detecting and preventing fraud and criminal activity, or pursuant to a court order;
- Credit reference agencies whom we use to assess fraud, credit and/or security risks;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where will your personal information be processed?
Many of the companies and other persons with whom we share your personal information are based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
- where we use providers based in the US, we may transfer data to them only when Standard Contractual Clauses are adopted and after an individual assessment and a case-by-case legal review.
Cookies are small text files that we transfer to your computer's hard drive to enable our systems to recognise your browser and help us to track visitors to our digital services so we can better understand what portions of our digital services best serve you.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
To find out more about the types of cookies we use on our digital services, how we use them and how you can change your cookies settings, please read our Cookies policy, available at www.threatessentials.com.
Please note that such third-party websites and applications are not under our control. When you click through to these websites or access these applications you leave the area controlled by us and you allow third parties to collect or share data about you. We are not responsible for the privacy statements of any third-party websites, and do not accept responsibility for any issues arising in connection with that third party's use of your personal data.
Protecting your personal information
Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you.
The transmission of information via the internet is not completely secure; this risk is common across the internet and not specific to our Digital Services. We do everything we can to ensure the security, integrity and confidentiality of your information.
It is important for you to protect against unauthorised access to your password and to your computing device. Be sure to sign off and close your browser when you have finished your user session. This will help to ensure that others do not access your personal information if you share your computing device or use a computing device in a public place such as a library or internet café.
How long do we keep your personal data for?
We only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the risk of harm from it being used or disclosed without our authority, the purposes for which we process it and whether we can achieve those purposes without it. We also take into account the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Registering a complaint
If you have a complaint or a concern about Threat Essentials Ltd’ information rights practices, you can report it to the Information Commissioner’s Office (ICO) at https://ico.org.uk/concerns/.
Updating your personal data and preferences
You may change your marketing preferences or update your personal information at any time by writing to Threat Essentials Ltd Customer Services, Threat Essentials Ltd c/o Work.Life, 33 Foley Street, London, W1W 7TL, United Kingdom, online via https://www.threatessentials.com or by emailing firstname.lastname@example.org. Should you wish to unsubscribe entirely from marketing communications, then please email email@example.com. We will process any requests of this nature as quickly as possible.
How to contact us
online via https://www.threatessentials.com/contact.
by email at firstname.lastname@example.org
by writing to us at: Threat Essentials Ltd c/o Work.Life, 33 Foley Street, London, W1W 7TL United Kingdom.