Who We Are

Total Conflict Management Limited (“TCM/The TCM Group”) is registered in England and Wales with the company number 04237876.

In this policy, “we”, “us” and “our” refer to The TCM Group.

Our registered office address is:

Unit 239 Business
Design Centre
52 Upper Street
London
N1 0QH

Our ICO Registration reference is ZA136214

The Law

• We are required under data protection legislation to notify you of the information contained in this privacy notice.
• This notice does not form part of any contract of employment, contract to provide services, or any other contract and may be updated at any time. We will inform you if this occurs.
• We will comply with data protection law. This says that the personal information we hold about you must be:

1) Used lawfully, fairly and in a transparent way.

2) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3) Relevant to the purposes we have told you about and limited only to those purposes.

4) Accurate and kept up to date.

5) Kept only as long as necessary for the purposes we have told you about.

6) Kept securely.

Our Committment

Our main objective is for you to have absolute trust and confidence in us when we collect, control and process your data.

We are committed to:

• Being completely transparent about how, when and why your data is controlled and processed by us.
• Allowing you control over the personal data we collect from you and how we process that personal data.
• Not using automated decision-making when processing your personal data.

It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.

Subject Access Requests

As a data subject, you are entitled to formally request information we hold about you.

We must provide you with a copy of this information, the reasons it is being processed and whether it will be given to any other organisations or people provided that you make this request in writing to our Data Protection Officer (DPO): Email: [email protected]

Post: The TCM Group, Unit 239, Business Design Centre, 52 Upper Street, London N1 0QH.

You can read more about Subject Access Requests at the Information Commissioner’s Office website.

SAR TIMESCALES

All Subject Access Requests will be completed within 30 days unless defined as complex.

If the time will exceed 30 days, you will be notified by the DPO address.

SAR FEES

Subject Access Requests coming directly from the data subject will be free. However, TCM can charge a fee if requests become unfounded or excessive. If requests come from another individual on behalf of a data subject, TCM may charge a fee for data retrieval.

Confidentiality & Security

We are committed to keeping the personal information provided to us secure, and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.

All of our employees, consultants, and workers who have access to and are associated with processing personal information receive training on confidentiality and security. They are obliged to respect the confidentiality of such personal information.

Concerns & Complaints

If you have any concerns or complaints relating to this policy, its subject matter, or how we collect, control and/or process your data, please do let us know by sending an email to our Data Protection Officer at [email protected] or write to us at our registered office address (see Who We Are section above).

Monitoring & Reviewing

TCM is committed to ensuring that our Privacy Notice is effective and up to date.

The Directors will review this document at least once a year or more frequently if needed due to changes in laws or practices.

Privacy Notice for Website Users

Under the Data Protection Act 1998 (“the Act”) and General Data Protection Regulation (Regulation (EU) 2016/679) (“the Regulation”), we are a data controller and data processor of personal data and sensitive personal data provided by you to us through our website.

We may collect and process personal data, sensitive personal data and other information from you when you use our website and its content.

The type of data collected and how such data is collected will vary depending on how you use our website and whether or not you have consented for us to collect certain types of data from you.

By using our website and/or our products or services in conjunction with our website, you agree that we collect and process the personal data provided as part of that process for the purposes made clear to you at that time.

 

How We Collect Personal Data

Personal and sensitive personal data may be collected by us actively and passively. The specific types of personal data we may collect from you are detailed below.

Necessary Data

This is data we must collect to provide you with access to content found on our website, as well as to enable you to access and use that content across multiple devices, to enable you to delete personal data when you wish, and/or for us to deliver information, content, or services that you request through the website.

We may also use Necessary Data to provide you with information about similar products and services we provide.

Necessary Data includes but is not limited to your name, email address and company information.

Necessary data will be collected by us when you fill in and submit the relevant form through the website.

Optional Data

This data includes information not necessary for us to collect but which you actively provide to us (“Optional Data”).

Optional Data includes but is not limited to information about your business and the reasons for using the website or company information.

We may also use Optional Data to analyse your requirements as a consumer and provide information about other products and services we provide that may interest you.

Optional Data will be collected by us when you submit a request for content through forms throughout the website which request that data.

You may be able to actively provide us, at any time in the future, with additional Optional Data if you choose to do so. We will collect and use that data following these terms.

Website Data

We may collect Device Information using the following technologies:

· “Cookies” are data files placed on your device or computer and often include a unique anonymous identifier. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org.

· “Log files” track actions occurring on the website and collect data, including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

· “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the site.

We passively collect this data while you use and browse the website. A list of Cookies used may be found at the following address: https://thetcmgroup.com/privacy-policy/

When you visit the website, we may automatically collect certain information about your device, including your web browser, time zone, and some of the cookies installed on your device.

In some cases, the information we collect – for example, your device information – can be used to help us improve and optimise our website.

We may also collect information about the web pages you view, what websites or search terms referred you to, and how you interact with the website.

For example, this information might be by generating analytics about how our visitors browse and interact with the website and assessing the success of any marketing and advertising campaigns.

Your Rights & Obligations

Updates to the Privacy Policy

We may update this policy from time to time by publishing a new version on our website.

You should check the following page occasionally to ensure you are happy with any changes to this policy: https://thetcmgroup.com/privacy-policy/

Consent

We will process your data with your express consent through opt-in mechanisms.

We may also process your data if applicable Legislation permits.

For example, we may be able to legally control and process your personal data without your express consent for direct marketing purposes if doing so is in the public interest, where it is necessary for the performance of a contract, or if we must do so to comply with local or national law.

We may also process your personal data without your express written consent if we have a legitimate interest in doing so, for some internal administrative purposes, or to ensure electronic information security.

Where we are processing your personal data based on you giving us your consent to do so, you have the right to withdraw that consent at any time, but this will not affect the lawfulness of the processing before the withdrawal of such consent.

You can exercise your right to withdraw consent to the processing at any time by contacting us via email at [email protected] or by updating your email preferences using the link provided in all emails.

You may prevent cookies from being stored concerning your visit to and use of our website, but please be aware that this may negatively impact how the website works.

Data Retention, Erasure and Rectification

The personal data we collect from you will be stored and retained by us for the time necessary to fulfil our services.

In general, we will retain your personal data as follows:

a) Enquiry data, customer relationship data and notification data will be retained for a minimum period of one month following the enquiry date and for a maximum period of 12 months following the enquiry date.

b) Correspondence data will be retained for a minimum period of one month following the date of correspondence and for a maximum period of five years following the date of correspondence.

We may also retain such data for a reasonable period after our engagements have ended to keep a record of our communications and how you have used the website or for any period as required by applicable law.

You have the right to erasure (the ‘right to be forgotten’).

This means that you have the right to request us to erase personal data we hold about you and that we should erase such data without undue delay if any of the below are applicable:

· That our processing of personal data is no longer necessary in relation to the purpose for which it was collected;

· That you withdraw your consent to the processing, and there is no other legal ground for us to continue to process the data;

· That you object to the processing under regulation 21 of the Regulation and there are no overriding legitimate grounds for the processing;

· That the personal data must be erased to comply with a national legal obligation.

You also benefit from the right to rectify inaccurate personal data we hold which relates to you (also known as the ‘right to rectification’). You can exercise your rights to erasure and rectification by contacting us via [email protected].

Sharing of Personal Data

We may disclose personal data we hold to third parties, with your consent or based on an otherwise lawful reason for doing so under the Legislation. For example:

· To facilitate, provide and improve the products and services we provide to you through our website;

· To analyse how our services are used by clients;

· In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets;

· If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets; and

· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements, or to protect our rights, property, or safety of our employees, customers, or others.

Use of Third-Party Platforms

Google Analytics

Our Platforms use Google Analytics, a web analytics service offered by Google, LLC.

Google Analytics uses small pieces of data, known as cookies, which can be used to track and analyse how you use and operate our Platforms.

Such data will be transferred to and stored on a server in the USA operated by Google, LLC, who may transfer this data to third parties where required by law or other third-party processors used by Google.

Google Ads

Our Platforms may utilise Google Ads, an online advertising service provided by Google, LLC.

Google Ads uses technologies like Flash and HTML5 for interactive ad formats and may use the IP address to identify your general location.

Google Ads employs cookies and other technologies to display targeted advertisements based on your interactions with our Platforms and other websites.

This data is transferred to servers operated by Google, LLC in the USA. Google may share this data with third parties when required by law or with affiliated third-party processors.

Google Ads products may also infer information about your location from various sources, such as search queries or websites you visit. Google ensures that ads are safe, discreet, and relevant.

Other Third Party Platforms

Our website may incorporate embedded assets from third parties, including but not limited to:

· YouTube videos.

· Google Maps.

· Other third-party integrations.

These embedded assets may collect data or set cookies on your device. We recommend reviewing the privacy policies of these third-party providers to understand how they manage data.

If you wish to avoid potential data collection from these assets, consider using browser settings or extensions to block third-party cookies or scripts.

Transfers Outside the EEA

Whilst the hosting facilities for our website are situated in the United Kingdom, usage data, enquiry data, customer relationship data and correspondence data are situated in the United States of America.

To ensure that your data is protected, we will apply appropriate safeguards, namely using standard data protection clauses adopted or approved by the European Commission.

External Links

When you click on links on our website, they may direct you away from our site.

We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

Children’s Privacy

The services provided through our website are not marketed to, and should not be used by, anybody under 18, and we do not knowingly collect personal data from children under 18.

If we discover that a child under 18 has provided us with personal data, we will delete such data from our servers unless consent is given or authorised by the holder of parental responsibility over the child.

 

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use:

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) Google Chrome;
(b) Firefox;
(c) Opera;
(d) Internet Explorer;
(e) Safari; and
(f) Edge.

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Our details

This website is owned and operated by The TCM Group Ltd.

Our principal place of business is at: The TCM Group, Unit 207, Business Design Centre, 52 Upper Street, London N1 0QH. Total Conflict Management Ltd t/a The TCM Group. Registered in England & Wales 4237876.

You can contact us:
(a)    by post, to the postal address given above;
(b)    using our website contact form;
(c)    by telephone, on 0800 294 97 87; or
(d)    by email, using [email protected].