Here at Foothold America, we’re committed to protecting and respecting your privacy. This applies to our wider business as well as our website.

Foothold America Limited( Foothold) and its subsidiary companies process personal information (Personal Data) every day.  This information is used by Foothold and their associates as part of their normal work. We take our duty to protect your Personal Data very seriously and all processing will be in line with the General Data Protection Regulation 2016 (GDPR).

Personal Data is any information by which an individual person can be identified. This includes a name, identification number, address, email address, IP address, photo, date of birth, and phone number. It also covers any factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person.

Processing includes the collection, recording, organising, storage, adapting, retrieval, use, erasure, or destruction of Personal Data.

We will take all reasonable means to keep your Personal Data confidential whether this is held on the computer, on paper, or other media. Every member of staff working at Foothold has a legal duty to keep information about you secure and confidential.

Who are we?

Our UK registered address is Allia Future Business Centre, Kings Hedges Road, Cambridge, CB4 2HY

If you have any questions about this policy, please contact our Data Protection Officer at:

Name:        Geanice Barganier

E-mail address:        gbarganier@www.footholdamerica.com

What Information do we collect?

Foothold aims to provide you with the highest quality of service. To do this we must keep records about you, and the services we provide you or plan to provide you. We collect Personal Data from you when you use our website https://www.footholdamerica.com/, contact by email, telephone, post, or any other method, and at meetings we hold.

The Personal Data we hold about you is protected by strict physical, electronic, and other means and includes but is not limited to:

• Basic details about you such as your name, address, and telephone number
• Any contact information that you give us when you register with us so that we can send you email updates, such as E-mail address
• IP address, geographical location, browser type, source of referral as well as which pages you visited and for how long.
• Services and Materials provided
• Financial details you provided
• Any information necessary for the delivery of our Services

We will also process Personal Data about our suppliers, employees, independent contractors, advisors, and professional experts.

We process your Personal Data in accordance with the GDPR. This will be to provide you with appropriate services or to meet contractual or legal obligations including maintaining our accounts and records or because you have consented to provide us with the information.

Foothold and their associates keep accurate and up-to-date information about the services you receive, and to enable them to provide you with the right advice about potential new services. It also ensures that any concerns you may have about your Services can be properly investigated.

If we intend to use the Personal Data for any other purpose, then you will be asked first unless required to act otherwise by law.

Some data is deemed Sensitive Data and we can only process this with your consent. If the consent is not forthcoming or withdrawn, we may not be able to fully deliver our Services with no liability on our part. Sensitive Data includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, sex life or sexual orientation, and medical information. We do not process such information in the normal provision of our services.

How is your information used?

We may use your information to:

• Respond to your queries, requests and other communications;
• Provide the Services, including, where applicable, procuring acts from foreign organisations;

• Send you communications which you have requested and that may be of interest to you.
• Enable suppliers and service providers to carry out certain functions on our behalf to provide the Services
• Administer our business, resolve complaints, troubleshoot our website, analyze data, test new features, develop and improve our services, notify your of changes to our services, or for research, statistical and suvery purposes.
• As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Please note that the provision of certain personal data is mandatory to comply with mandatory client due diligence requirements and consequently to provide the Services. If you are unable to provide the relevant personal data required to comply with our legal obligations and/or our terms of business, we may not be able to provide the services to you.

Who we may share your information with.

Information will be seen by Foothold staff, contractors, and others delivering services. There is sometimes a need to share information about you with other Third-Party providers so that we can work together to provide you with the best possible service to meet your needs. We will only ever share your information when there is a legitimate need to do so.

It may also be necessary to share some information with:

• Suppliers
• Business associates and other professional advisers
• Financial organisations
• Official bodies
• Service providers including online system providers such as TriNet, HubSpot, WordPress, Google.

In addition, we may disclose information about you:

• to the extent that we are required to do so by law;
• in connection with any legal proceedings or prospective legal proceedings;
• to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
• to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.

We never share personal data with any other organisation for third party marketing purposes.

We will not sell or rent your information to third parties.

The Legal Basis for the Processing

The legal basis for the processing shall be necesary:

• for the performance of a contract to which the individual is a party or to take steps at the request of the individual before entering into a contract.
• to comply with our legal obligations.
• for our legitimate interests or those of a third party except where overridden by the interests of the individual.
• for the performance of a task carried out in the public interest.
• to protect the vital interests of the data subject or another natural person.
• with your given consent

Security of Processing

When you give us personal information, we take great care to ensure that it is treated securely. We have strict procedures and security features in place to try to prevent unauthorised access.

We will take reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information.

We store all the personal information you provide on our secure (password- and firewall-protected) servers. Some of this data may be stored in secure servers outside the EU. It may also be processed by people operating outside the EEA who work for one of our suppliers. When you submit your personal data to us, you give your consent to it being stored and processed in this way.

All electronic transactions you make to or receive from us containing sensitive information are encrypter using SSL technology.

We take great care to ensure any confidential information remains protected, but we cannot guarantee the security of data sent over the Internet.

Transfers

It may sometimes be necessary to transfer Personal Data overseas. When transfers are needed, information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with all aspects of GDPR and follow the country-specific legislation.

Marketing

We want to keep in contact with our Clients, and those who have enquired about our services and to update them about our products, services, team news, promotions or information they might find useful by email and newsletters.

Any marketing communication sent to you has an option for you to unsubscribe should you not wish to receive any further materials.

Opting out and updating your personal information

You have the right to withdraw consent at any time. Please note that we may not be able to provide our Services if you withdraw consent for us to use your personal data. You can also update your personal information at any time.

Keeping your information accurate and up to date

We will make sure that the information we hold about you is accurate and up to date. We may check with you from time to time to make sure we have the right information about you, and where relevant, your next of kin. If the information is not correct, you can ask us to change it.

Your data subject rights

Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal information. Your rights are explained below:

Right to make a subject access request (SAR)

Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other data subjects. Each request should make clear that a SAR is being made. SARs must be in writing and accompanied by proof of your identity and address. If you want specific information e.g. a particular time frame, please clarify this. If someone is requesting information on your behalf, we shall need your written consent and evidence of ID for both of you.

Right to rectification

Data subjects may request that we rectify any inaccurate or incomplete personal data.

Right to withdraw consent

Data subjects may at any time withdraw their consent to the processing of their personal data carried out by the business based on previous consent.

Right to object to processing, including automated processing and profiling

We do not make automated decisions. We may use third party due diligence platforms which provide recommendations about data subjects by automated means. We will comply with any data subject’s objection to processing unless we have a compelling overriding legitimate ground for the processing, the processing is for the establishment, exercise or defence of legal claims or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.

Right to erasure

Data subjects may request that we erase their personal data. We will comply unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our archiving obligations that we must comply with.

Restriction

Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.

Right to data portability

In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used, and machine-readable format and have it transferred to another provider of the same or similar services. To the extent such right applies to the Services, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be required for legitimate and lawful purposes.

Right to lodge a complaint with the supervisory authority.

We suggest that data subjects contact us about any questions or complaints in relation to how we process personal data, however, each data subject has the right to contact the relevant supervisory authority directly.

How long do we keep your records?

We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal data for marketing purposes.

We may keep an anonymized form of data, which will no longer refer to you and therefore is not considered to be personal data, for statistical purposed without time limits.

Cookies

The internet pages of Foothold uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain what is called cookie ID. A cookie’s ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID. By using cookies, Foothold can provide the users of their website with more user-friendly services that would not be possible without the cookie setting.

Using a cookie, the information and offers on the Foothold website can be optimised with the user in mind. Cookies allow us to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookies are stored on the user’s computer system. The data subject may, at any time prevent the setting of cookies through our website using a setting on their browser being used and so deny the setting of cookies. Already set cookies may be deleted at any time via the internet browser. This is possible on all popular internet browsers. If an individual deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable. For more information on how we use cookies, check out our Cookie Policy.

Links to other websites

Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit – we are not responsible for the privacy notices and practices of other websites, even if you access them using links from our website.

Review of this Privacy Notice

We review our policies on a regular basis and may update this Privacy Notice by posting a new version on our website.

You should check this page occasionally to make sure you are happy with any changes. We may also notify you of changes to our privacy notice by email.