Introduction

Outlier Ltd (Outlier) takes your privacy very seriously and we are committed to protecting your personal information. This Privacy Policy explains how we collect and use information you give us when viewing our website. Please read this policy carefully.

We will manage and treat your personal data with respect. We will collect, store and manage it in an unbiased and secure way. We will only use your data for purposes that we have informed you about. We will always be transparent about the personal data we collect and how we use it.

This privacy policy will inform you as to how we look after your personal data when you use our services (regardless of where you access them from) and tell you about your privacy rights and how the law protects you.

If you have any questions, please contact [email protected]

 

  1. Important Information

Purpose of this privacy policy

This privacy policy aims to give you information on how Outlier collects and processes your personal data when we provide our services, including any data you may provide to Outlier whether through this website or any other means when you access our products or Services.

Outlier’s Services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Outlier is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the contact details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Outlier Ltd

Email address: [email protected]

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 policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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

This website 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 website, we encourage you to read the privacy policy of every website you visit.

 

  1. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We collect personal information about:

  • Clients that purchase our Services (or the key contacts that work for our clients) (Clients);
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
  • Contact Data includes billing address, delivery address, email address and telephone numbers;
  • Financial Data includes bank account and payment card details;
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
  • 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 this website, any Assessment, and/or any of the other Services or products of Outlier;
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
  • Usage Data includes information about how you use our website, products and services; and
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

You may give us information about you by filling in any form on our website or by corresponding with us by phone, email or otherwise.

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).

 

  1. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

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

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; give us feedback or contact us;

 

  1. Automated technologies or interactions.

The Outlier website is hosted by GoDaddy, GoDaddy collects personal data to power our site analytics, including:

  • Information about your browser, network, and device
  • Web pages you visited prior to coming to this website
  • Your IP Address

This information may also include details about your use of this website, including:

  • Clicks
  • Internal links
  • Pages visited
  • Scrolling
  • Searches
  • Timestamps

GoDaddy captures this information to help us to learn about site traffic and activity.

  • This website uses cookies and similar technologies. A cookie is a small text file that may be placed on your device (computer, mobile phone, tablet) when you visit our website. This cookie allows us to give your visit a unique identifier. You can configure your browser to notify you when cookies are being placed on your computer. You can also turn cookies off and delete those you do not want.

 

For information about viewing the cookies dropped on your device, visit Use of Cookies Policy – GoDaddy UK. These functional and required cookies are always used, which allow GoDaddy our hosting platform, to securely serve this website to you. These analytics and performance cookies are used on this site, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.

 

  • This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:
  • Information about your browser, network, or device
  • Your IP Address
  • This website is hosted by GoDaddy, GoDaddy collects personal data when you visit this website, including:
  • Information about your browser, network and device
  • Web pages you visited prior to coming to this website
  • Your IP Address

GoDaddy needs the data to run this website, and to protect and improve its platform and services. GoDaddy analyses the data in a de-personalised form.

 

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For information about viewing the cookies dropped on your device, visit: Use of Cookies Policy – GoDaddy UK. These functional and required cookies are always used, which allow GoDaddy our hosting platform, to securely serve this website to you. These analytics and performance cookies are used on this site, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.

 

  1. 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 we need to perform the contract we are about to enter into or have entered into with you.
  • 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 obligation.

We have set out below, in a table format, a description of all 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

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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 website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us

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, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased Services from us 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 third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

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 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.

 

  1. Disclosures of Your Personal Data

We may share your personal data with our Client in the context of the provision of Services to them in connection with any Assessment undertaken. Individual responses may be disclosed to Clients, containing an overall Assessment score and additional comments about a Participant’s performance. We may pass all of your information to a third party 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 policy.

 

  1. International Transfers

We may from time to time appoint third parties to process data containing information about you on our behalf as a data processor or store such information in or transfer it to persons located in countries outside of the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded 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.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. 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.

 

  1. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

  1. Your Legal Rights

Under certain circumstances, you have rights under data protection laws to:

  • request access to your personal data;
  • request correction of your personal data;
  • request erasure of your personal data; object to processing of your personal data;
  • request restriction of processing your personal data;
  • request transfer of your personal data; or
  • right to withdraw consent.

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

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 could 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 could 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.

 

  1. Glossary

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

  • External Third Parties includes: (1) Service providers acting as processors who provide IT and system administration services; (2) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; (3) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.