PROTECTING YOUR PRIVACY

1. Introduction
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We want you to be fully informed about your rights, and how Drum Cussac uses your data; for example we will cover things such as your platform user profile, any financial transactions and our interactions with travel management companies and security providers on your behalf.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Policy from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

 

2. What is Drum Cussac Group Limited?

Drum Cussac Group Limited – which we’ll refer to as ‘Drum Cussac’ in this document – also comprises our subsidiary, Drum Cussac Inc. However, if you’re based anywhere outside the UK and order from us, you will be trading with Drum Cussac Group Limited and therefore this Privacy Policy applies to all international orders. See section 16.

For simplicity throughout this policy, ‘we’ and ‘us’ means Drum Cussac and its brands.

 

3. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box online to receive specific product or service information, intelligence and analysis whitepapers or by email response for direct marketing services.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if your employer’s travel management company provides us with your travel itinerary, we’ll process those details to ensure you receive our travel risk management technological services during your trip.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we can use your personal data to request customer feedback or marketing surveys to help us improve our products and services.

 

4. When do we collect your personal data?

  • When you visit any of our websites or applications.
  • When you make an online purchase (CloseCircle subscription).
  • When you create a platform user login and profile.
  • When you pay/settle an invoice for a product or service by phone.
  • When you engage with us on social media.
  • When you download or install one of our apps.
  • When you contact us by any means with queries, complaints etc.
  • When you ask us to email you information about a product or service.
  • When you book any kind of appointment with us or book to attend a Drum Cussac event.
  • When you choose to complete any surveys or feedback requests we may send you.
  • When you comment on or review our products and services online, by phone or email.
  • Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the individual/third party supplier who provided that service, it may be passed on to them if requested.
  • When you fill in any forms. For example, OverWatch or Journey Management request forms.
  • When you’ve given a third party permission to share with us information they hold about you.
  • We may collect data from publicly-available sources (such as Credit Reference Agencies) when you have given your consent to share information or where the information is made public as a matter of law.
  • When you use our office car park which usually has CCTV systems operated for the security of both us and our visitors. These systems may record your image during your visit.

 

5. What sort of personal data do we collect?

  • If you have a platform user profile: your name, contact details, email address, department (optional, if provided), location, IP address and travel itinerary and booking details. For your security, we’ll also keep an encrypted record of your login password.
  • Details of your interactions with us through our Global Operations Centre, Account Managers, online, email and telephone.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of legal and financial transactions we make, brands you show interest in, and how and when you contact us.

  • Copies of documents you provide to prove your age or identity (where the law requires this), which in the case of your passport will include details of your full name, date of birth, place of birth, gender, nationality and facial image.
  • Details of your visits to our websites or apps, and which site you came from to ours.
  • Data from publicly available lists and third parties that you have agreed can share data with us.
  • Your comments and product or service reviews.
  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located (IP address), the web pages viewed during your visit, and any search terms you entered. Learn more about this.
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

We’ll only ask for and use your personal data collected for delivering the services we are contractually obliged to do, recommending products and services of interest and to improve your browsing and internet interactions with us. Of course, it’s always your choice whether you share such details with us.

 

6. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you products and services that are most relevant to you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for or we are contractually obliged to deliver.

Here’s how we’ll use your personal data and why:

  • To process any orders that you make by email, website, app or by phone. If we don’t collect your personal data for payment, we won’t be able to process your order and comply with our contractual obligations.

For example, your details may need to be passed to a third party to process a payment or supply a service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as a refund.

  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  • To protect our business and you from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your platform user profile. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

  • To protect people, premises, assets and our business from crime, a CCTV system is operated which records images for security. This is done on the basis of a legitimate business interest.
  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
  • If we discover any criminal activity or alleged criminal activity through use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
  • With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

Of course, you are free to opt out of hearing from us by all or any of these channels at any time.

  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you.

For example, updates to product or service release notices and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

  • To administer any of our marketing promotions or competitions which you enter based on your consent given at the time of entering.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.

  • To comply with our contractual or legal obligations to share data with law enforcement.
  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by notifying our Data Protection Officer at dpo@drum-cussac.com

  • To process your security support requests (for example in the event of an SOS – emergency evacuation). Sometimes, we’ll need to share your details with a third party that is providing a service (such as an executive protection service provider, airline or hotel). We do so to deliver our contractual obligations with you, and without sharing your personal data we’d be unable to fulfil your request. See section 10.

 

7. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Drum Cussac as described above. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the publicly available data lists mentioned above.

 

8. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to our websites and apps using ‘https’ technology and access to your personal data is password-protected, and secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

 

9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

An example data retention period:

Contracts

When you place an order by contractual agreement, we’ll keep the personal data you give us for seven years so we can comply fully with our legal and contractual obligations.

In the event of contract termination we’ll completely delete the personal data (or anonymise it as described above) after 30 days, or by contractually agreed data retention period.

 

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, payment transaction providers, security service providers, for fraud management, to handle complaints, to host our technology services and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.
  • They may only use your data for the exact purposes we specify in our contract with them.
  • We work closely with them to ensure that your privacy is respected and protected at all times.
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

  • IT companies who support our website, technology platforms and other business systems.
  • Operational companies such as external security service providers.
  • Email marketing companies that help us manage our electronic communications with you.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

  • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For example, if you enter a competition and tick a box agreeing that Drum Cussac or a partner direct marketing company can send you promotional information directly. Or if we run a joint event with a partner direct marketing company, and you agree to receive direct communications from them.

  • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our clients into consideration.
  • We may, from time to time, expand, reduce or sell Drum Cussac and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Policy.
  • For further information please contact our Data Protection Officer.

 

11. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to Drum Cussac in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data sub-processors in countries that are outside the EEA.

For example, this might be required in order to provide in-country security support services during your travel, or airline and hotel services in evacuating you to safety.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.

 

12. What are your rights over your personal data and how do I exercise them?
An overview of your different rights

You have the right to request:

  • To be informed – typically through a Data Privacy Notice or Privacy Policy such as this.
  • Access to the personal data we hold about you; there may be a small administrative charge.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • Erasure of your data (also known as the right to be forgotten).

For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a contract’s retention period).

  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that Drum Cussac holds at any time and also to have that information corrected if it is inaccurate. To exercise any of your rights under our privacy policy and GDPR, please contact Data Protection Officer, Drum Cussac Group Limited, Avalon, 26-32 Oxford Road, Bournemouth BH8 8EZ, or email dpo@drum-cussac.com.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy.

 

13. How can you stop the use of your personal data for direct marketing?
There are the ways you can stop direct marketing communications from us:

  • Click the ‘unsubscribe’ or ‘opt-out’ link in any email communication that we send you. We will then stop any further emails from that particular division.
  • Write to Data Protection Officer (Marketing), Drum Cussac Group Limited, Avalon, 26-32 Oxford Road, Bournemouth BH8 8EZ.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

 

14. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling +44 (0) 303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

 

15. If you live outside the UK
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in or outside of the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and backup servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Policy. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

 

16. Any questions?

We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at dpo@drum-cussac.com

Or write to us at Data Protection Officer, Drum Cussac Group Limited, Avalon, 26-32 Oxford Road, Bournemouth BH8 8EZ

This policy was last updated on 25/04/2018