We may collect, use, store and transfer the following types of personal data:
- Identity data: including first name, last name, marital status, title, date of birth and gender;
- Contact data: including residential address, email address and telephone number;
- Technical data: including IP address used to connect your computer or mobile device to the internet, browser type and version, operating system and platform and other technologies on the devices you use to access www.baringa.com or baringa.ai.
We use different methods to collect personal data from you, including through:
- Direct interactions. For example, when we interact with you for business purposes or contact you with business related information that we consider may be of interest to you. Also, if you make an enquiry or submit a job application you will be asked to provide certain information including name, email address and telephone number.
- Automated technologies or interactions. When you interact with our websites we may automatically collect information about your equipment, browsing action and patterns This information is collected through cookies. A cookie is an element of data that both www.baringa.com and baringa.ai send to your browser which is then stored on your system. You can set your browser to prevent this happening. Any information collected in this way can be used to identify you unless you change your browser settings.
We do not collect sensitive data about you without your express consent and would only do so in accordance with data privacy laws and the Cookie notice.
“Sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment. Such categories included racial or ethnic origin, political opinions, biometric and genetic data, criminal records, religious beliefs and physical and mental health.
How we use your personal data
We only use your personal data where required for specific purposes. Most commonly, we will use your personal data in the following circumstances:
- To contact you with business related information that we consider may be of interest to you;
- Where it is necessary for our legitimate interests (e.g. conducting our business in an efficient and compliant manner and the overall promotion of our business) and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation
Unless we consider we have a legitimate business reason for contacting you, we will only contact you with your consent, and you have the right to withdraw your consent at any time.
We process any personal data for website operations, security logging based on our legitimate interests; marketing communications based on consent or legitimate interests; and compliance-related processing where necessary to meet our legal obligations.We do not sell, rent or exchange your personal information with any third party for commercial reasons.
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.
Use of AI-enabled chatbot services
We provide an AI-enabled chatbot to assist visitors in navigating baringa.ai and obtaining information about Baringa and its services. The chatbot generates responses using information from:
- content published on www.baringa.com and www.baringa.ai;
- other authorised public sources; and
- information provided by users.
When using the chatbot, users should avoid submitting personal data, sensitive data, confidential information or any personal data relating to other individuals.
We may collect and retain records of chatbot interactions for operational, security, compliance, troubleshooting, quality assurance and service improvement purposes.
Please be aware that content which is generated by the chatbot should not be relied upon to make important decisions as it may occasionally be inaccurate, incomplete or out of date. Chatbot responses should not be relied upon as legal, professional, financial or other regulated advice. Should you require advice, please contact Baringa to liaise with a human representative.
Data retention
We maintain a specific data retention policy to ensure that we only retain your personal data for as long as necessary to fulfil the purpose 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 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 through other means, and the applicable legal requirements.
Chatbot logs
We will keep records of chatbot interactions with users with all technical logs being hosted and stored within the United Kingdom.
Access to the chatbot logs is restricted to only authorised personnel or employees of Baringa who need to access the information for service, support, security or operational purposes.
Records generated will be kept in accordance with Baringa’s data retention policies and for only as long as necessary to fulfil the purposes set out in this Privacy Policy.
International transfers
We may from time to time wish to transfer personal data to our other group entities or third parties supporting the operation of our business which may involve transferring data outside the European Economic Area (EEA).
Prior to making any such transfer of personal data, we will take the necessary steps to ensure that a similar degree of protection is afforded to your personal data in accordance with the applicable data privacy laws. Where such transfers occur, we use appropriate safeguards such as adequacy regulations, the UK IDTA, the UK Addendum to the EU Standard Contractual Clauses, or the EU Standard Contractual Clauses.
AI transparency notice
Users of the chatbot should be aware that the chatbot is supported by an AI system and not by an individual.
Responses which are generated by the chatbot use publicly available information and, given an AI system is involved, some of the outputs may not be accurate, up-to-date or complete.
Any response which is generated by the chatbot should not be relied upon as the basis for making important decisions. Where appropriate, a user should seek professional or relevant alternative third party advice to make such decisions. If a user requires assistance from a human representative, they should contact Baringa directly.
The above transparency notice is intended to satisfy Baringa’s transparency obligations in accordance with the relevant AI regulations and laws, including, where applicable, the EU AI Act.
Your legal rights
Under certain circumstances, by law, you have the following rights in relation to your personal data:
- Request access to your personal data (commonly known as “data subject access request”): this enables you to receive a copy of your personal data and to check that we are lawfully processing it;
- Request a rectification to your personal data: this entitles you to have any incomplete or inaccurate personal data corrected;
- Request the erasure of your personal data (often referred to as the “right to be forgotten”): this entitles you to request your personal data be deleted 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 information where you have exercised your right to object to processing (below);
- Object to the processing of your personal data: this entitles you to request that we no longer process your personal data;
- Relating to automated decision-making – to challenge decisions based solely on automated processing where legally applicable.
- Request the restriction of the processing of your personal data: this entitles you to request that we suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interest but we need to hold some of it for the purpose of legal proceedings;
- Request transfer of your personal data: this entitles you to receive a copy of your personal data, or request we transmit such personal data to another party; and
- Withdraw your consent at any time: where we are relying on consent to process your personal data you may withdraw this consent at any time by contacting us at privacy@baringa.com.
Contact us
Please do not hesitate to contact us, using the details below, if you:
- have any questions about privacy or this particular statement
- wish to exercise your rights in relation to your personal data rights
- wish to make a complaint about our use of your data
Email address: privacy@baringa.com
Postal address: Baringa Partners LLP, 62 Buckingham Gate, London, SW1E 6AJ, UK
Telephone number: 0203 327 4220
If, despite our commitment and efforts to safeguard your personal data, you have any concerns or complaints about our privacy activities, you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.