Introduction
We are FullCircl ("FullCircl", "us", "our" or "we"), a trading name of Artesian Solutions Ltd (ICO registration number Z3428795). We provide a platform and services with access to intelligence on more than 50 million companies (“Platform”). As our name suggests, our Platform is used by our customers for due diligence, risk assessment and corporate intelligence. You can find out more about who we are and what we do on www.fullcircl.com. This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing the Platform. This policy also provides contact details and important information about data protection rights. This policy was last updated July 2024. We will periodically update this policy so please check back for updates.
What personal data do we collect?
Company directors and shareholders
We collect personal data relating to company directors and shareholders from publicly available registers. The information we collect includes:
- Name
- Date of birth (month and year)
- Corporate appointments, shareholdings and relationships
- Politically Exposed Person details
- Sanctions (current and previous)
- Financial regulator penalties
- Law enforcement information(including criminal offence information)
- Bankruptcy
- Adverse media
We will also collect any personal data contained in or generated via correspondence with company directors and shareholders. If a residential address has been used as a company’s registered office, we will also collect that information. We collect information relating to company directors and shareholders in the following countries:
- United Kingdom
- Ireland
- Albania
- Belgium
- Bermuda
- Cyprus
- Denmark
- Finland
- France
- Germany
- Greenland
- Guernsey
- Hong Kong
- Hungary
- Iceland
- Isle of Man Israel
- Italy
- Jersey
- Latvia
- Lichtenstein
- Lithuania
- Luxembourg
- Malta
- Montenegro
- Netherlands
- Norway
- Poland
- Portugal
- Romania
- Slovakia
- Slovenia
- Sweden
- Switzerland
Platform users
We collect personal data relating to individuals who access our Platform as employees, agents, representatives or officers of our customers. The information we collect comes directly from Platform users and, where applicable, our customers. It includes:
- Product purchase, order and payment information
- Profile data (including login details, Platform usage, interests, preferences, survey responses and feedback)
- Contact details (including telephone number and email address)
- Device information (including browser type, plugins, operating system, time zone setting and location, IP address)
- Marketing and communications data (including preferences)
- Cookie data (please see cookie section below)
Website users
The information we collect from people who visit www.fullcircl.com includes:
- IP address
- Website usage
- Cookie date (please see cookie section below)
- Personal data entered to webforms
People we work with
We collect personal data directly from individuals we work with. We collect personal data from their employers or the organisations they represent. We also collect personal data relating to people we work with from other organisations we work with (for example, industry conferences, media, social media, other platforms and industry partners). The personal data we collect relating to people we work with includes:
- Name
- Address
- Contact details (including telephone and email)
- Social media
- Professional and employment details
- Personal data in correspondence
- CCTV
- Visitor details
How we use personal data
Company directors and shareholders
We use personal data we collect relating to company directors and shareholders to provide insight into companies as part of providing, developing and promoting the Platform. We also use personal data relating to directors and shareholders to respond to correspondence as well as to exercise legal rights and comply with legal obligations.
Platform users
We use the personal data relating to Platform users to:
- Provide. develop and promote the Platform
- Improve the Platform by providing personalised content, language, help and instructions
- Customize the Platform by location
- Provide customer service assistance
- Ask people to participate in surveys, products, services, news and events
- Better understand how the Platform is used (including checking traffic patterns and what types of content are most popular)
- Receive and respond to correspondence
- Exercise legal rights and comply with legal obligations
Website users
We use personal data relating to users of our websites mainly to provide, develop and promote our websites, Platform and wider business. More specifically, we use personal data relating to website users to:
- Provide customer service assistance
- Better understand how our websites are used (including checking traffic patterns and what types of content are most popular)
- Website analytics and improvements
- Detect and address security risks
- Detect fraud and other unlawful activity
- Exercise legal rights and comply with legal obligations
People we work with
We use personal data relating to people we work with mainly to provide develop and promote our Platform and wider business. More specifically, we use personal data relating to people we work with to:
- Mange orders to suppliers and from customers
- Arrange events
- Manage business and professional relationships
- Detect and address security risks
- Detect fraud and other unlawful activity
- Exercise legal rights and comply with legal obligations
Our legal grounds to use personal data
Directors and shareholders
Our legal ground for using personal data relating to directors and shareholders is that doing so is necessary for the purposes of legitimate interests pursued by FullCircl and our customers. Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust due diligence. This includes commercial due diligence and legal obligations to carryout due diligence, such as anti-money laundering (“AML”) and know your client(“KYC”) checks.
We consider that commercial and legal due diligence are crucial to a strong economy and safe society. Consequently, we consider that they provide a compelling ground for us to process personal data relating to directors and shareholders. We have carried out a legitimate interests assessment of our use of personal data relating to directors and shareholders.
We consider that, as all the personal data we collect for the Platform is publicly available, the interests and rights and freedoms of directors and shareholders do not override our legitimate interests and particularly do not override the compelling legitimate interests of our customers. Where we use criminal offence information or special category personal data relating to directors and shareholders we do so for the purposes of preventing and detecting crime.
Platform users
Contract
If we have a contract with a Platform user, we will use personal data relating to them where necessary for the performance of that contract.
Legitimate interests
We will also use personal data relating to Platform users where necessary for the purposes of legitimate interests pursued by FullCircl and our customers. This includes using personal data relating to an employee, agent, representative or officer of a customer for the purposes of administering the customer’s account and providing the Platform. However, we will only use personal data relating to Platform users for the purposes of legitimate interests where Platform users’ interests and rights freedoms do not override our legitimate interests or the legitimate interests of our customers.
Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust due diligence. This includes commercial due diligence and legal obligations to carryout due diligence, such as anti-money laundering (“AML”) and know your client(“KYC”) checks.
We have carried out a legitimate interests assessment of our use of personal data relating to Platform users. We consider that the interests and rights and freedoms of Platform users do not override our legitimate interests and particularly do not override the compelling legitimate interests of our customers.
Consent
Our legal ground for sending Platform users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be with drawn at any time.
Website users
Legitimate interests
We will also use personal data relating to website users where necessary for the purposes of legitimate interests pursued by FullCircl. We will only use personal data relating to website users for the purposes of legitimate interests where website users’ interests and rights freedoms do not override our legitimate interests or the legitimate interests of our customers.
Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust due diligence. We have carried out a legitimate interests assessment of our use of personal data relating to website users. We consider that the interests and rights and freedoms of website users do not override our legitimate interests or the legitimate interests of our customers.
Consent
Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be with drawn at any time.
People we work with
Legitimate interests
We use personal data relating to people we work with where necessary for the purposes of legitimate interests pursued by us. Our legitimate interests include for the purpose of providing, developing and promoting our Platform and wider business.
We will only use personal data relating to the people we work with for the purposes of legitimate interests where their interests and rights freedoms do not override our legitimate interests.
Consent
Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.
Automated decision-making
We do not make any legally significant decisions about individuals based solely on automated decision-making.
Sharing personal data
Directors and shareholders
We share personal data relating to directors and shareholders with Platform users, our customers and our staff.
We share personal data with the following types of service providers:
- IT providers
- Professional service providers (for example, accountants and lawyers)
We have contracts in place with these service providers that strictly govern how they may use the personal data we share with them. We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving FullCircl and/or the Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
Platform users
We share personal data relating to Platform users with their employers or the customer on whose behalf they are accessing the Platform, our staff and the following types of service providers:
- Payment processors
- Advertising partners(see cookies section below)
- Analytics service providers (see cookies section below)
- IT providers
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving FullCircl and/or the Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
Website users
We share personal data relating to website users with our staff and the following types of service providers:
- Advertising partners(see cookies section below)
- Analytics service providers (see cookies section below)
- IT providers
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving FullCircl and/or the Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
People we work with
We share personal data with our staff and the following types of service providers:
- Online stores
- Payment processors
- IT providers
- Marketing partners
- Group companies
- Sister studios
- Business partners
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving FullCircl or our Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
Cookies and similar technologies
Cookies are small information files that we place on the devices used to access www.fullcircl.com and the Platform. The types of Cookies we use are described below.
Essential cookies
Our website and Platform will not work properly without essential cookies. For example, we and our service providers may use essential cookies to identify and authenticate Platform users. We also use essential cookies to provide customer service (including tracking customer journey and analytics for support purposes), enforce our Terms of Use and maintain the security of our website and the Platform. The essential cookies we use on the Platform include:
- Heap
- New Relic
- Full Story
- Google / reCAPTCHA
The essential cookies we use on the website include:
- Google / reCAPTCHA
Non-essential performance or analytics cookies
Non-essential performance or analytics cookies collect information and analytics about how people use our website. For example, which pages users visit most often and error messages received by users from web pages. We always seek consent for the use of analytics cookies on the website. We do not use non-essential performance or analytics cookies on the Platform.
The analytics providers we use on the website include:
- Heap
- HubSpot
- Leadfeeder
- Visme
- Vimeo
- Advertising cookies
Advertising cookies are used to deliver advertisements relevant to visitors based on the visitor’s interests and to measure the effectiveness of advertising campaigns.
These cookies are usually placed by advertising networks with our permission.
They remember that you have visited the website and this information is shared with other organisations such as advertisers.
We always seek consent for advertising cookies on our website. We do not use advertising cookies on the Platform.
The advertisers we work with on the website include:
- Eventbrite
- HubSpot
Children
We do not knowingly collect or use any personal data relating to children.
International transfers
Where we transfer personal data outside the UK to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses or other appropriate safeguard or we will identify an appropriate exemption.
Data retention
Directors and shareholders
We keep personal data relating to directors and shareholders for the time that the director or shareholder appears on the relevant publicly available corporate register.
Platform users
We keep personal data relating to Platform users for up to six years after the end of our agreement with them or their employer or the customer on whose behalf they are accessing the Platform.
Website users We keep personal data relating to website for as long as necessary for our business purposes.
Rights
Everyone has the right to:
- Information about how we use personal data (which is what this policy is for)
- Access to personal data
- Object to the use of personal data
- Erasure of personal data
- Portability of personal data
- Withdraw consent where our use of personal data is based on consent
- Rectification of personal data
- Restriction of personal data
- Complain to your supervisory authority
Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or they are not relevant. The Information Commissioner’s Office provides more information about data protection rights - www.ico.org.uk.
If a director or shareholder asks us to delete personal data relating to them that is from a publicly available source, we will only do so where their circumstances override the compelling legitimate interests we pursue.
If you do not provide personal data
Where we need personal data for an agreement with you under our Terms and you do not provide that personal data, we may not be able to perform out agreement. In this case, we may have to cancel your access to the Platform.
Our contact and DPO details
Call us
(0)330 321 0101
Email us directly
enterprise@fullcircl.com
Our office
Runway East, Chapter House
18 Crucifix Lane
London SE1 3JW
Website
https://www.fullcircl.com/contact-us
Data Protection Officer
If you would like to contact our Data Protection Officer ("DPO"), please email privacy@fullcircl.com
EEA Data Protection Representative
If you would like to contact our EEA Representative, please email eu.privacy@fullcircl.com
Our EU representative is registered in Dublin, Ireland.
International standards
We follow these international standards relating to personal data:
- ISO/IEC 27001:2013 Information technology -- Security techniques -- Information security management systems -- Requirements
- ISO/IEC 27002:2013 Information technology -- Security techniques -- Code of practice for information security controls
- ISO/IEC 29134:2017 Information technology -- Security techniques -- Guidelines for privacy impact assessment
- ISO/IEC 29151:2017 Information technology -- Security techniques -- Code of practice for personally identifiable information protection
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