Privacy Policy
Last updated: September 19, 2024
Table of contents
- About this notice
- Who we are
- What we do
- Our role
- How we collect and use your information
- Who is the information shared with?
- Your rights
- Data Protection Officer
- Complaints
1. About this notice
This privacy notice explains what personal data we collect from or about you. It sets out why we collect, use, and protect your personal data, and what rights you have over that data.
2. Who we are
BehaviourLab Limited are located at:
Mortimer House, 1st Floor
37-41 Mortimer Street
W1T 3JH
United Kingdom
44 20 7139 4404
info@behaviourlab.com
behaviourlab.com
We are registered in the UK at Companies House under number 11722806.
3. What we do
Behaviour Lab is an industry‑leading software and analytics firm that helps portfolio managers and asset owners improve their investment performance and decision‑making processes. We provide scalable software solutions and advisory services tailored to individuals, teams, and organisations.
4. Our role
Typically, we act as a processor of your personal data as it relates to the services that we provide to our customers and who manage your data. This means that we only process data about you to provide our service to our customers, or on the instructions of our customers that use us to provide their services. For information on how our customer uses your personal data, including how we fit into that processing, you should review their privacy notice or contact them for more information. This notice only applies to the personal data we process as a controller. This means when we are responsible for deciding how we collect, use and store information about you.
5. How we collect and use your information
How we collect and use your personal data will depend on how you interact with us or the services you use. To better understand how we use your data, please click on the role that best describes you.
I am just browsing your website
We want to process as little personal information as possible when you use our website. That's why we've chosen Fathom Analytics for our website analytics, which doesn't use cookies and complies with the UK GDPR, GDPR, ePrivacy Directive, including UK PECR, COPPA and CCPA. Using this privacy-friendly website analytics software, your IP address is only briefly processed, and we (running this website) have no way of identifying you. As per the CCPA, your personal information is de-identified. You can read more about this on Fathom Analytics' website. The purpose of us using this software is to understand our website traffic in the most privacy-friendly way possible so that we can continually improve our website and business. The lawful basis for this processing is our legitimate interests to improve our website and business continually. No personal data is stored over time.
I am contacting you via your contact form or email
Purpose your data is used
We will need some of your personal data to process your question from your use of the website contact form or when contacting us via email. We may also process your data to respond to your request for a demo and other enquiries about our services. This allows us to establish contact and respond to your question. If you contact us via the input mask in the contact form, you can object to the storage of your personal data at any time. Users may revoke consent or object to data processing by sending a written request. All personal data that was saved in the course of making contact will be deleted in this case.
Type of data used
Name, email address, organisation, data and time of contact, the content of your communication.
Legal basis
Legitimate interests. If the purpose of your contact is establishing a contract, we rely on performance of a contract.
How long we keep your data
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
I am a user of your product
When your employer uses our services, we need to process some of your information. Some data is provided to us by your employer in the context of the contractual relationship they have with us and for which we provide our services, while other personal data will then be obtained from you directly. To find out more information about how our service, and therefore your data, is processed by us in the context of your employment, you need to speak to your employer. We only use your data for this purpose on the instructions of your employer. Below we have outlined the reasons we use your data, the data used, and how long it is kept for.
Purpose your data is used
We process the personal data of our customer, as well as the data of its employees that is shared with us. In order to provide our services, we also process some additional information of employees to understand their investment behaviour for managing and analysing cognitive bias.
Type of data used
Name, email address, phone number, company name, position/title, emotions/views/opinions on investment decisions, signatures, financial transaction IDs.
Legal basis
Performance of a contract
How long we keep your data
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.
I am a candidate for a job position
Purpose your data is used
When you apply for open positions advertised on our website, you can submit your application via email. To process your application and manage the interview process, certain personal data is required as part of standard interview and application processes.
Type of data used
Title, name, email address, phone number, address, educational background, linguistic proficiency, CV, testimonies/referrals.
Legal basis
Performance of a contract. Where your data may be kept in an applicant pool, this is done on the basis of your consent.
How long we keep your data
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.
Our company presence and communications with you through professional networks
Purpose your data is used
We maintain a company presence on some professional networks. This applies for LinkedIn. We may process some of your personal data through these networks to communicate with you. Our presence on professional social networks also serves to inform users about our services.
Type of data used
Name, title/position, contact details, professional background.
Legal basis
Legitimate interests
How long we keep your data
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.
Hosting
Purpose your data is used
The company website is hosted on servers by a service provider commissioned by us. Our service provider is AWS. The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. This data is not merged with other data sources. The website server is geographically located in Ireland.
Type of data used
Browser type and version, operating system used, referrer URL, host name of the accessing computer, data and time of server request, IP address.
Legal basis
Legitimate interests
How long we keep your data
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.
What do we mean by “legal basis”?
We are only able to use your personal data when the law allows us to. This is called the legal basis. Regarding the above purposes, the legal basis listed for each are explained below:
Consent – You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. To do so please contact us via the details supplied below.
Contract – We need to use your data to fulfil a contract you have with us. Alternatively, it’s necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.
Legal Obligation – We need to use your data to comply with the law.
Vital Interests – Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.
Public Task – Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law, for example, for a statutory function.
Legitimate Interests – Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.
This includes our legitimate interests for:
- Gathering required personal data for the establishment of a business relationship, lead generation and opportunity verification, and subsequent establishment of a business relationship, as well as the fulfilment of our services to you as a customer.
- Managing our communications with you for the process of complaints or customer service discussions to ensure the operational effectiveness of our business.
- Establishing a business relationship where you are a supplier or service provider we wish to engage with for the support of our services.
- Facilitating our marketing practices to businesses and business individuals to further the expansion of the business and generate opportunities.
- Managing some aspects of our application processes and managing your application for a role in order to establish an employment contract.
6. Who is the information shared with?
As with most organisations, we use service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them. This includes payment service providers, service providers to support our communications and systems, providers of customer support, and email service providers. We have agreements in place with all our providers that oblige them to protect your data, and we require all service providers to keep your personal data confidential. Where your data is transferred outside of the UK, we make sure that your data is given the same level of protection, either because that country has a comparable data protection standard (known as Adequacy), or by using another safeguard such as an enhanced contractual agreement. Sometimes, we may be legally obliged to supply copies of personal information to other organisations. For example, to supply information to the police. We might not be always able to tell you that we have shared your information in this way, however we will ensure this is only shared in accordance with the law.
7. Your rights
Under data protection legislation, in certain circumstances you have the following rights over the processing of your personal data as described in this notice:
- right to be informed about how your data is used;
- right of access to your personal data;
- right to correction or rectification of your data;
- right to request deletion of your data; and
- the right to data portability. In most cases, we must respond to a request to exercise these rights within one month if not before. If you would like to submit a request, please contact us at info@behaviourlab.com
8. Data Protection Officer
The contact details for our Data Protection Officer are as follows:
By post: DataCo International UK Limited
Suite 1, 7th Floor, 50 Broadway
London, United Kingdom
SW1H 0BL
By email: privacy@dataguard.co.uk
By phone: +442035146557
9. Complaints
If you are unhappy with any aspect of this privacy notice, or how your personal data is being processed, please contact us. If you are still not happy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
By post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
By live chat: Live Chat
By email: casework@ico.org.uk
By phone: +44303 123 1113
Contact Us