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Privacy & Fair Processing Notice

This Privacy Notice is issued on behalf of Leyton UK Ltd, a company registered in England and Wales with the company number 06977112 and with its registered office at 13-15 Bouverie Street, Harmsworth House, London, England, EC4Y 8DP and THESEE MAROC, a company registered in Morocco with the company number 245533 and with its registered office at Plt 501, Shore 14, 5ème étage, Parc Casanearshore – Sidi Maârouf – Casablanca (together “Leyton UK”). When we use the terms "we", "us" or "our" in this privacy notice, we are referring to the relevant Leyton entity responsible for processing your data. We will let you know which entity will be the controller for your data when you contract with us.

Leyton UK strive to protect the privacy of all personally identifiable information collected during the course of our activities and it is important for you to know how we process your data. We will process your personal information under the terms of this notice and in accordance with any agreement with you.

We are “data controllers” in terms under data protection laws (including from 25 May 2018, the EU General Data Protection Regulation 2016 and the Data Protection Act 2018) (“Data Protection Laws”).

We need to process personal data relating to our R&D customers, our suppliers, the employees of our R&D customers and potential customers in order to function effectively as a business, perform contracts and services, to ensure good governance, for audit purposes and to enable us to meet our legal obligations.

Personal data is processed for commercial, administrative, statutory and marketing/promotion purposes. All such personal data is collected and held in accordance with all applicable Data Protection Laws.

This list includes all the ways we may use your personal information, and which of the reasons we rely on to do so. This is where we tell you what our legitimate interests are.

Personal Information We May Process:

Our Reasons for Processing

Our Legitimate Interests

R&D Customers

  • Name
  • Email address
  • Contact details
  • Contracts and invoices that customer has with third parties
  • Financial documents
  • Payroll details
  • Fulfilling contracts
  • Consent
  • Our legitimate interests
  • Administering our business
  • To perform our services
  • To keep in contact with our R&D Customers and, where appropriate, to offer Leyton UK’s similar or related services

Suppliers

  • Contact details
  • Financial details
  • Bank details
  • IP addresses
  • Our legitimate interests
  • Administering our business
  • To keep in contact with suppliers
  • Fulfilling contracts
 

Employees of Leyton’s R&D customers

  • Company director ID such as passport or driving license for anti money laundering (AML) purposes
  • R&D employees’ professional experience and qualifications
  • Remuneration figures and start/end dates of employment for R&D employees and/or that of the support staff members’ involved in R&D projects
  • Fulfilling contracts
  • Consent
  • Our legitimate interests
  • Administering our business
  • To perform our services
  • To keep in contact with our R&D Customers and, where appropriate, to offer Leyton UK’s similar or related services

Employees and workers of Leyton’s R&D customers’ suppliers:

  • Personal data contained within invoices sent to Leyton customers. Such invoices may include an individual employee’s timesheet and charge out rates for the duration of work carried out for Leyton customers.
  • Our legitimate interests
  • Required by the R&D team to provide our services

Potential customers and clients (B2B only)

  • Name
  • Contact details
  • Our legitimate interests
  • For customer research and prospecting purposes
  • Including sending marketing information to potential customers and clients in compliance with any applicable laws relating to marketing
  • Fulfilling contracts
  • Consent
 

In most cases we will obtain this information from you directly. However, where you are an employee, a worker or a supplier of a customer or client of ours, we may obtain personal details about you from your employer using the reasoning contained within in the table, above.

We may also obtain information about you, if you are a prospective customer, via the DUEDIL database (a private company information database).

We process the personal data referred to above for the purposes of any contract or potential contract with our R&D customers and our suppliers; or for our legitimate interests in order to function effectively as a business, to ensure good governance, for audit purposes, to perform our business activities; and to enable us to meet our legal obligations that we may be subject to.

Who do we share your information with?

The information you provide to us may be accessed and processed by our staff and we may share it with our auditors, our professional advisors and carefully selected third parties in the course of providing services to us (such as IT services) under suitable obligations of confidentiality.

In particular, we may share your information with the following entities:

  • Salesforce (“Salesforce”). If you are a customer or a potential customer of Leyton, your personal data may be transferred to Salesforce, our CRM cloud provider.
  • Purple Lattice (“Purple Lattice”). Purple Lattice is Leyton’s IT support services provider, therefore, if you are a customer of Leyton your personal data, and, where appropriate, the personal data of your employees, may be accessed by Purple Lattice for system maintenance purposes.

We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our activities.

As you interact with our websites, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using “cookies” and other similar technologies to help improve the performance of our websites by allowing it to remember you based on your last visit, present tailored options to you, measure web traffic and track user journeys. Please see our cookie policy for further details.

We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.

Please be aware that unfortunately the transmission of information via the internet or by email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to us and any transmission is at your own risk.

We will retain personal data securely and only in line with how long it is necessary to keep for the purposes or for a legitimate and lawful reason.

Our typical retention periods are as follows:

Personal Data Held Within:

Retention Period:

Supplier contracts and documentation

7 years from the date of expiry or termination of the last supplier contract

R&D customer contracts and documentation

7 years from the date of expiry or termination of the last customer contract

Anti-money laundering ID for R&D customers

7 years from the date of the last client instruction

Names and emails addresses of both potential and existing customers used by the sales team

7 years from the date which the potential customer last responded to solicitation of Leyton

 

Some personal data may be retained for longer where it is in our legitimate interest to do so, such as to protect and defend our legal rights; or for research, archiving or statistical purposes. Individuals can request that other information relating to them be erased and we will deal with such requests in accordance with the law.

We, or carefully selected third parties that we contract with, may send personal data to countries outside the European Economic Area (‘EEA’). If and when this occurs, there will be protections in place to ensure the recipient protects the data to the same standard as the EEA. The protections include:

  • Transferring to a non-EEA country with privacy laws that give the same protection as the EEA.
  • Putting in place a contract with the recipient that means they must protect personal data to the same standards as the EEA.
  • Transfer personal data to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for personal data sent between the US and EU countries which makes sure standards are similar to what is used within the EEA.

In particular, personal data relating to employees of Leyton’s R&D customers, (existing and prospective) may be passed to and from THESEE MAROC, an associate Leyton company registered in Morocco, in order to provide services to such customers and deal with business needs (including but not limited to the provision of IT support services) and such sharing is set out in a written data sharing agreement and/or data processing agreement (as appropriate).

As an individual, you have the following rights as a data subject under applicable Data Protection Laws in relation to the processing of your personal data:

  • The right to request from us access to information held about you - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • The right to request that inaccurate data held about you is rectified - this enables you to have any incomplete or inaccurate information we hold about you corrected.
  • The right to request the erasure of personal data - this enables you to ask us to delete or remove personal information 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.
  • The right to restriction of processing - this enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • The right to object to processing - objection to processing of your personal information can occur where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes; and
  • The right to data portability.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Privacy Manager in writing.

Where we process your personal data based upon your consent, you have the right to withdraw your consent at any time.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Privacy Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

For more information and guidance about any of these rights please go to the website of the Information Commissioner’s Office at https://ico.org.uk/

If you think there is an issue in the way in which we handle your personal data, you have a right to raise a complaint with the Information Commissioner’s Office. Their website contains details of how to make a complaint.

We keep our Privacy & Fair Processing Notice under regular review and reserve the right to update and amend it. This notice was last updated in May 2019.

For further information about the proposed data sharing set out in this notice, or about any aspect of Leyton and the processing of your personal data, please contact our Data Privacy Manager:

Ingrid McGhee
Data Privacy Manager
8th Floor,
Lomond House,
9 George Square,
Glasgow, G2 1DY
0141 375 9750
DPM@leyton.com