Accipi Privacy Policy

Welcome to Accipi Limited’s privacy notice.
Accipi Limited (“ACCIPI”, also referred to as “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we use and look after your personal data when you visit or use our website, app, platform or other services (the “Services”), and tells you about your privacy rights and how the law protects you.

This privacy notice is divided into specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY/DEFINITIONS

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice
This privacy notice aims to give you information on how ACCIPI collects and processes your personal data through your use of our Services, such as when you sign up directly to/register with ACCIPI, or otherwise use our Services for example as a registered or unregistered respondent to third party surveys. Our Services are not intended for children and we do not knowingly collect data relating to children under 13.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

We are a Data Controller
ACCIPI is the data controller and directly responsible for control of and making decisions about your personal data when you sign up directly to/register with ACCIPI or otherwise use our Services for example as a as a registered or unregistered respondent to third party surveys.

ACCIPI is also a data processor (on behalf of our customers as data controllers) when you access the Services under someone else’s account. For example if your employer or educational institution has a contract with us for their use of ACCIPI to create surveys which enables you to use the platform through their contract with us. In this situation we have no independent control over your data and merely act on the instructions of the data controller in order to provide them the Services. The Privacy Notice does not apply in that situation.

Queries and Complaints
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details:
Full name of legal entity: ACCIPI Limited, company number 07142802
Email address: info@accipi.com
Postal address: The White House, 2 Meadrow, Godalming, Surrey, United Kingdom, GU7 3HN
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
This version was last updated on February 2024.
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.

Third-party links
Our Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity information has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data (if you register with us) may include first name, maiden name, last name, username or similar identifier.
Contact Data (if you register with us) may include address, email address and telephone numbers.
Profile Data (if you register with us) may include other information or data you submit to use when registering or otherwise interacting with ACCIPI, including information about your activity on ACCIPI such as the type of surveys you have responded to or are otherwise interested in.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Usage Data includes information about how you use our Services.
Marketing and Communications Data (if you register with us) includes your preferences in receiving marketing from us and any third parties, 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific platform feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not routinely 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). However, on occasion this may be requested in relation to a particular project of survey opportunity, in which case we will obtain your specific consent to collect and use it. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with registered or signed up access). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity or Contact by registering with us, filling in forms, or by corresponding with us by email, message, post, phone or otherwise. This includes personal data you provide when you:

register for or log into any part of our Services;
subscribe to any part of our Services or publications;
request marketing to be sent to you;
enter a competition, promotion or reward opportunity; or
give us some feedback.

Third parties. We receive personal data about you from various third parties including Technical Data from certain third parties or analytics providers such as Google.
Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you have registered with us and we need to perform the contract we have therefore entered into with you to supply with access to certain Services.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

See the Glossary at the end of this notice to find out more about the types of lawful basis that we will rely on to process your personal data, and what the above wording means.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message, or in relation to Special Category Data as set out above. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below in the table a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user, respondent or other participant on ACCIPI, or for a newsletter, download or similar registration	Identity Contact	Performance of a contract with you to supply with access to certain Services
To provide you with the Services or access to the Services, and to manage our service relationship with you which may include: instructions and information about how to use the Services notifying you about changes to our Services, terms or privacy policy asking you to leave a review or give feedback about ACCIPI	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you to supply with access to certain Services Necessary to comply with a legal obligation Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business, and to keep our records updated and to study how customers use our products/services)
To enable you to partake as a registered respondent in third party surveys or other projects; and to have the opportunity to receive rewards	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you to supply with access to certain Services
To deliver relevant content and suggestions to you and measure or understand the effectiveness of the content we serve to you	Identity Contact Profile Technical Usage Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services including other third party surveys that may be of interest to you – see the Marketing and Suggestions section below for more information	Identity Contact Profile Technical Usage Marketing and Communications	Performance of a contract with you to supply with access to certain Services Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our products / services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our services updated and relevant, to develop our business and to inform our marketing strategy)
To administer and protect our business and this Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

Marketing and suggestions about further third party surveys.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and recommendations.

Third party survey suggestions from us
We may use your Identity, Contact, Technical, Usage Data and Profile Data to form a view on how you have used ACCIPI, and what we think may be of interest to you, including through what surveys you have responded to before . This is how we decide which services may be relevant for you, including what other surveys you may be interested in. You may receive such marketing communications, suggestion and offers from us if you registered / signed up to ACCIPI and you have not opted out of receiving that marketing.
Marketing and promotional offers from us
We may use your Identity, Contact, Technical, Usage Data and Profile Data to form a view on what we think may be of interest to you. This is how we decide which other promotions and offers may be relevant for you. You may receive such marketing communications, promotions and offers from us if you registered / signed up to ACCIPI and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside ACCIPI for marketing purposes. We will never share your personal data with Researchers without your consent.
Opting out
You can ask us or third parties to stop sending you marketing messages by contacting us or them at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service registration, service interactions or other transactions.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly. For more information about the cookies we use, please see or Cookie Policy.
Change of purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below (for the purposes set out in the table in paragraph 4 above).
External Third Parties:

Service providers acting as processors for us, under our instruction, who provide for example IT and system administration services, or other technical or creative services to us.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
We will never share your personal data with researchers or third party survey providers without your consent.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

6. INTERNATIONAL TRANSFERS
We may transfer your personal data outside the UK or European Economic Area (EEA). If we do we will take additional steps in order to ensure that your personal data is treated safely and securely under relevant Data Protection Legislation.

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION
How long will you use my personal data for?
We will only retain 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 potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.

10. GLOSSARY/DEFINTIONS
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means you have given clear consent for us to process your personal data for a specific purpose.