PRIVACY POLICY OF SAPID RESEARCH LTD

Sapid Research Ltd, is committed to keeping any and all personal information collected of those Individuals that visit our website and ma e use of our online facilities and services accurate, confidential, secure and private. Our privacy policy has been designed and created to ensure those affiliated with Sapid Research Ltd of our commitment and realization of our obligation not only to meet but to exceed most existing privacy standards.

Therefore, this Privacy Policy Agreement shall apply to Sapid Research Ltd and thus it shall govern any and all data collection and usage thereof.

Using www.sapidresearch.com and any subsidiary website listed below you are herein consenting to the following data procedures expressed within this agreement.

Collection of Information
This website collects various types of information, such as:
• Voluntarily provided information which may include your name, address, email address, other pertinent business card information
• Information automatically collected when visiting our website, which may include cookies, third party tracking technologies and server logs.

Please rest assured that this site shall only collect personal information that you knowingly and willingly provide by way of surveys, completed membership forms, and emails. It is the intent of this site to use personal information only for the purpose for which it was requested, and any additional uses specifically provided on this site. We may also gather information about the type of browser you are using, IP address or type of operating system to assist us in providing and maintaining superior quality service.
It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand the way in which other websites garner, ma e use of and share information collected.

Use of Information Collected
Sapid Research Ltd may collect and may ma e use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. At times, we may find it necessary to use personally identifiable information to keep you informed of other possible products and/or services that may be available to you from www.sapidresearch.com and our subsidiaries.
Sapid Research Ltd may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future
services that may be offered.
Sapid Research Ltd does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties. We do however, provide your information to strategic digital partners with whom you share your expressed permissions per any subscription you may have.
Sapid Research Ltd may feel it necessary, from time to time, to contact you on behalf of other external business partners with regards to a potential new offer which may be of interest to you. If you consent or show interest in presented offers, then, at that time, specific identifiable information, such as name, email address and/or telephone number, may be shared with the third party.
Sapid Research Ltd may find it beneficial to share specific data with our trusted partners to conduct statistical analysis, provide you with email and/or postal mail deliver support and/or arrange for deliveries to be made.
Those third parties shall be strictly prohibited from making use of your personal information, other than to deliver those services which you requested, and as such they are thus required, in accordance with this agreement, to maintain the strictest of confidentiality with regards to all your information.
Sapid Research Ltd may deem it necessary to follow websites and/or pages that our users may frequent to gleam what types of services and/or products may be the most popular to customers or the general public.
Sapid Research Ltd may disclose your personal information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
• Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process both nationally and internationally which may be served upon Sapid Research Ltd and/or our website. Laws and statues such as GDPR, EDPR, CASL, etc.
• Maintain, safeguard and/or preserve all the rights and/or property of Sapid Research Ltd; and Perform under demanding conditions in an effort to safeguard the personal safety of users of www.sapidresearch.com and/or the general public.

GDPR Compliance:
The EU General Data Protection Regulation (GDPRR” comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and training a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment
We are committed to ensuring the security and protection of the personal information that we process and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR as well as all other compliance laws.
Sapid Research Ltd are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, for purpose and demonstrates an understanding of, and appreciation for the new regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How We are Preparing/ Have Prepared for the GDPR

Sapid Research Ltd already has a consistent level of data protection and security across our organization, however it is our aim to be fully compliant with the GDPR and remain fully compliant.

Our preparation included: –
· Information Audit – carried out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
Policies & Procedures – [revising/implementing new] data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
Data Retention & Erasure – we have updated our Retention policy and schedule to ensure that we meet the ‘data minimization and ‘storage limitation principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subjects’ rights apply; along with any exemptions, response timeframes and notification responsibilities.
Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – where Sapid Research Ltd stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
o Subject Access Request SAR” – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to ta e for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
· Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to.
Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
· Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR,
ensuring that all individuals whose personal information we process have been informed of why
we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
· Obtaining Consent – we have maintained and strengthened our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
· Direct Marketing – we [have revised] the wording and processes for direct marketing,
including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
· Data Protection Impact Assessments DPIA” – where we process personal information that is considered high risks, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
· Processor Agreements – where we use any third-party to process personal information on our behalf i.e. Payroll, Recruitment, Hosting etc.”, we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they as well as we”, meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
· Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via [our websites] of an individual’s right to access any personal information that Sapid Research Ltd processes about them and to request information about: –
· What personal data we hold about them
· The purposes of the processing
· The categories of personal data concerned
· The recipients to whom the personal data has/will be disclosed
· How long we intend to store your personal data for
· If we did not collect the data directly from them, information about the source
· The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
· The right to request erasure of personal data where applicable” or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
· The right to lodge a complaint or see judicial remedy and who to contact in such
instances Information Security & Technical and Organizational Measures
Sapid Research Ltd takes the privacy and security of individuals and their personal information very seriously and ta e every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: –
SSL, access controls, password policy, encryptions, pseudonymization, practices,
restriction, IT, authentication on all levels of our organization.

GDPR Roles and Employees
Sapid Research Ltd have designated Sean Flint as our [Data Protection Officer DPO(s)] and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Sapid Research Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans.
We have implemented an employee training program specific to which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Sean Flint privacy@sapidresearch.com Children under Age of 13
Sapid Research Ltd does not knowingly collect personal identifiable information from children under the age of thirteen 13” without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of thirteen 13”, we shall immediately ta e the necessary steps to ensure that such information is deleted from our system’s database. Anyone under the age of thirteen 13” has no reason to be on our site and will be immediately black listed.

Unsubscribe or Opt-out
All users and/or visitors to our website have the option to discontinue receiving communication from us and/or reserve the right to discontinue receiving communications by way of email or newsletters. To discontinue or unsubscribe to our website please send an email that you wish to unsubscribe to privacy@sapidresearch.com. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe and/or opt-out.

Security
Sapid Research Ltd shall endeavour and shall take every precaution to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to
prevent any loss, misuse, unauthorized access, disclosure or modification of the user’s personal information under our control. The company also uses Secure Socket Layer (SSL) for authentication and private communications in an effort to build users trust and confidence in the internet and website use by providing simple and secure access and communication of credit card and personal information.

Changes to Privacy Policy Agreement
Sapid Research Ltd reserves the right to update and/or change the terms of our privacy policy, and as such we will post those change to our website homepage at www.vereigenmedia.com, so that our users and/or visitors are always aware of the type of information we collect, how it will be used, and under what circumstances, if any, we may disclose such information. If at any point in time Sapid Research Ltd decides to ma e use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected; the user or users shall be promptly notified by email. Users at that time shall have the option as to whether or not to permit the use of their information in this separate manner.

Acceptance of Terms
Through the use of this website, you are hereby accepting the terms and conditions stipulated within the aforementioned Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use of our sites. In addition, your continued use of our website following the posting of any updates or changes to our terms and conditions shall mean that you are in agreement and acceptance of such changes.

How to Contact Us
If you have any questions or concerns regarding the Privacy Policy Agreement related to our website, please feel free to contact us at the following email, telephone number or mailing address.
Email: Privacy@sapidresearch.com
Telephone Number:  +44 (020) 7097 7118
Mailing Address:
Sapid Research Ltd
71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ