Privacy policy

Table of Contents

General

The information on this website is provided by Parallel 51 Ltd. Parallel 51 Ltd is registered in England and Wales with company number 10530679 and its registered office at First Floor, 10 Queen Street Place, London, England, EC4R 1BE. The principal place of business and correspondence address of Parallel 51 Ltd is Marlborough House, Marlborough Crescent, Newcastle upon Tyne NE1 4EE.

 

Corterum is a regulatory compliance solution provided by Parallel 51 Ltd to enable FCA-registered businesses efficiently discharge their regulatory duties under various regulations including the Senior Manager and Certification Regime (SM&CR).

 

Our website is: https://corterum.com

 

The protection of your personal data is important to us. We collect your personal data when you use the Corterum application (the “App”) and when you use our websites (a “Website” or “Websites”). We use that data for marketing, sales, the operation of your Corterum account and employment purposes. We are committed to the lawful, fair, transparent, accountable, accurate, confidential, and limited collection and processing of your personal data.

The types of Personal Information we collect and why

We may require basic information which identifies you as an individual (“Personal Information”), such as your name, email address and phone number, in order to transact business with you, on behalf of the company you work for, as our customer.  We will only use such Personal Information for the purposes of providing information which you have requested, fulfilling business transactions, or for other purposes set out in this policy.

Parallel 51 Ltd may also collect Personal Information indirectly from third parties, such as our business partners, or members of your Community.

We may collect the following information, depending on your use of Corterum:

  • Identification data (including, without limitation, name, address, date of birth, NI number);
  • Contact data (including, without limitation, email addresses/telephone numbers (home and work));
  • Position data (including, without limitation, title/role/grade/job description);
  • Details of communications (including, without limitation, emails from or to or about them);
  • Contractual data (including, without limitation, copies of employment contracts or details of directorship);
  • Location data and IP address data;
  • Financial data;
  • Employment details (including, without limitation, employment history, disciplinary proceedings data, data specific to the role performed by the data subject or background checks);
  • Data pertaining to the fitness and propriety of an individual to perform his/her role pursuant to the Senior Managers and Certification Regime which may include the results of Disclosure and Barring Service checks;

As part of the Corterum service we may collect sensitive information in relation to racial or ethnic origin, but we do not collect sensitive information such as political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, or data concerning health or sexual orientation.

Finally, we may also ask for your personal data when you express an interest in employment opportunities at Corterum by applying through our careers page. The information we collect from you will be made apparent at the time you are submitting your application, and we will use this information only to evaluate your employment candidacy and to comply with our certifications and legal obligations.

Purposes for processing Personal Information

Business transactions with our customers

We process Personal Information through Parallel 51’s IT systems, which include tools and systems that help us to administer customer accounts, orders and business transactions and share information across our systems, and with related corporate entities, as described elsewhere in this policy. Parallel 51 Ltd may host this information on our servers or utilize third party servers and applications, but in either case will be responsible for the security access of Personal Information on the systems.

Corterum

You may provide Personal Information to Parallel 51 Ltd through our “registration” page for Corterum and in the ongoing operation of the Corterum service.

We may make use of Personal Information that we collect to help us administer the Corterum product and platforms:

  • To analyze system usage to help maintain the operational system
  • To enable you to access customer support portals or to provide customer support services to you
  • To optimize system operation based on usage and enable future product development and improvements
  • To enable our compliance with laws and regulations

 

The Internet is a global environment and using the Internet to collect and process data can involve the transmission of data on an international basis. By using our Corterum and communicating electronically through the SaaS products, you acknowledge our processing of data in this way.

The Corterum service allow users to send documents and communicate with other users. Parallel 51 Ltd is not responsible for the data protection or privacy practices or the content of other users’ sites. When your communications leave our platforms, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this policy. You should review the data protection and privacy statements applicable to such sites.

Our Website and the Corterum service may use cookies. Most browsers allow you to turn off cookies or to receive a warning before a cookie is stored on your hard drive. Find out more about our cookies in our Cookie Notice.

If you do not wish us to make use of your Personal Information in this way, please email [email protected].

Other legitimate business purposes

We may also collect and use Personal Information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently, for example, for information security/management.

Legal purposes

We also may use your personal information where we consider it necessary for complying with laws and regulations, or to exercise or defend the legal rights of Parallel 51 Ltd.

Who we share your Personal Information with

Within Parallel 51 Ltd

Employees, contractors and agents of Parallel 51 may be given access to Personal Information which we collect, but their use will be limited to the performance of their duties and the reason for processing. Our employees, contractors and agents who have access to your Personal Information are required to keep that information confidential and are not permitted to use it for any other purposes. All access to users’ Personal Information within the Corterum App is logged and recorded.

Corterum’s Data is hosted on AWS servers, on data centers which are located in the United Kingdom.

Business partners and service providers

Parallel 51 Ltd will never sell, rent or disclose to unaffiliated third parties your Personal Information unless we have your permission or are required by law to do so. When we permit a third party to access Personal Information, we will implement appropriate measures to ensure the information is used in a manner consistent with this policy and that the security and confidentiality of the information is maintained.

Parallel 51 Ltd discloses the Personal Information it collects to the following third parties:

  • HubSpot – to manage the sales and marketing contacts of Parallel 51 Ltd
  • AWS – to enable the hosting of Corterum App data and the provision of service.
  • Intercom – to deliver help, customers service and support
  • Stripe – to manage the collection and administration of payments.
  • Any other third parties where disclosure is required or authorized by law

 

Each of these are governed by their own privacy policies – see the links above for more information.

Lawful grounds

We may disclose Personal Information to third parties on other lawful grounds, including:

  • To comply with our legal obligations, regulation or contract, or to respond to an administrative or judicial process
  • In response to lawful requests by public authorities (including for national security or law enforcement purposes)
  • If necessary to exercise or defend against potential, threatened or actual litigation
  • If necessary to protect the vital interests of another person
  • In connection with the sale, assignment or other transfer of all or part of our business, or
  • With your consent.

Controlling your Personal Information

You can request correction, update and deletion of your Personal Information via e-mail sent to [email protected], and we will use reasonable efforts to contact you regarding your request. To update or delete your Personal Information or correct an inaccuracy, we may ask you to verify your identity and cooperate with us in our effort.

EEA residents only

Transfer of Personal Information

We may need to occasionally transfer Personal Information to countries other than the ones in which the information was originally collected, for example where data held by third party partners is processed outside of the United Kingdom. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area to a country outside it, such as the United States, we will implement an appropriate data export solution such as entering into EU standard contractual clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law.

Privacy rights

If you are a resident of the European Union, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. You can exercise these rights by contacting us using the contact details provided in Section 5 above.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Data retention

Personal Information will be retained no longer than necessary in relation to the business purposes for which such Personal Information is provided and to fulfil legal requirements.

Security

We are committed to ensuring that your information is secure. We have put in place appropriate technical, physical and administrative procedures to safeguard and secure the information we collect in order to prevent unauthorised access or disclosure.

Updates to this policy

Parallel 51 Ltd reserves the right, in its discretion, to make changes to any part of our products, platforms or this policy.  We may change the policy from time to time by updating this page. You should check this page from time to time to ensure that you are aware of any changes. This policy is effective from 01/01/2021. By continuing to use Corterum products and services, you consent to this policy as amended.

Contact Information

If you have any questions about this policy, or wish to make a complaint about our data handling practices, you may contact:

Data Protection Officer

Parallel 51 Ltd

10 Queen Street Place,

London,

EC4R 1BE,

United Kingdom.

Parallel 51 Ltd. Registered in England & Wales. Company No. 10530679

We are contactable by email.

Appendix 1: Cookie Policy

What are cookies and how do they work?

“Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the website to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Like most websites, we use different categories of cookies for a variety of purposes in order to improve your online experience.

What are the categories of cookies?

Cookies can be categorised, following the International Chamber of Commerce guide, as follows:

  • Strictly necessary cookies

Strictly necessary cookies tend to be session cookies which are deleted at the end of the browser session. Accepting these cookies is a condition of using the website, so if you prevent these cookies we can’t guarantee how our website will perform during your visit.

  • Performance cookies

‘Performance cookies’ collect information about how you use our website such as which pages you visit and if you experience any errors. These cookies don’t collect any information that could identify you – all the information is collected on an anonymous aggregate basis and is only used to help us improve how our website works, understand what interests our users and measure the effectiveness of our advertising. They also enable us to track the total number of visitors to our site. Most performance cookies tend to be session cookies which are deleted at the end of the browser session.

In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above. Some of these third party performance cookies are persistent cookies.

  • Functionality cookies

Functionality cookies, by their very nature, are persistent cookies so that we remember your computer when you return to our website.

Some of these cookies are managed for us by third parties – where this is the case we don’t allow the third party to use the cookies for any purpose other than those listed above.

How can I block and/or delete cookies?

Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can easily delete any cookies that have been installed in the cookie folder of your browser.