Privacy Policy

Aletha Research Privacy Policy

Aletha Research Limited (“Aletha”), registered in London, United Kingdom, under the company number 15027452. Registered on the address 7 Bell Yard, London, WC2A 2JR, London, United Kingdom.

Aletha understands that privacy is important and is committed to respecting your privacy and protecting your personal data. This policy sets out our approach to the collection, storage, usage and transfer or disclosure of information you provide to us and information we collect in the course of operating our business or in connection with this site. 

Personal Information Types

We currently collect and process the following information:

• Information that you provide when using the site, including names, contact details and business enquiry, necessary for client relationship management
• Information contained or relating to any communications you send to us or send through using the site, including meta data, cookie identifiers and website user statistics, associated with the communication

Information supplied for the above purposes may include names, addresses, telephone numbers, email addresses any other additional information that you may supply, or which may be otherwise processed.

Personal Information Use

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Marketing 
• Site administration
• Client relationship management
• Enquiries and complaints 
• Securing the site and its systems
• Fulfilling contractual obligations
• Meeting legal, regulatory and compliance obligations
• Where relevant, for the establishment, exercise or defence of legal claims
• Compiling anonymous statistical data about the use of the website to improve its content

Personal Information Legal Basis

Aletha processes personal data to enter into, or perform a contract; to comply with legal obligations; optimise our website; and, maintaining client relationships.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are: 

• Your consent. You are able to remove your consent at any time. You can do this by contacting Aletha.
• We have a contractual obligation.
• We have a legal obligation.
• We have a legitimate interest, including commercial or individual interests

Data Subject’s Rights

You have the right at any time to ask us for a copy of your personal data that we hold. If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. Therefore, please advise us of any changes to your information. You have the right to request that personal data we hold is erased under certain circumstances.

Personal Information Storage

Your information is securely stored. Personal data is stored no longer than is necessary for the purposes for which it was processed. We may nevertheless retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject to.

Personal Information Processed for Services

This Privacy Policy primarily relates to personal data collected and processed as a result of operating our business or your interaction with the site. However, in the course of providing our to clients, we may process personal data on individuals who are the subject of, or relevant to, those services.  

In accordance with GDPR or other applicable data protection laws, where Aletha is a controller of the personal data in relation to due diligence services, Aletha does not provide fair processing notices to such individuals as to do so would seriously impair the achievement of the objectives of that processing. We treat all such data in accordance with our obligations under GDPR or other applicable data protection laws. We make this statement in compliance with our obligation under article 14(5)(b) GDPR to publicize that nature of the information that would otherwise be contained in any such fair processing notice.

The data will be collected for the purpose of providing our services to our clients. The lawful basis under GDPR, or analogous data protection laws, for such data processing will vary depending on the nature of the data and the project, but will include:

• Aletha's client’s legitimate interests
• Prevention or detection of an unlawful act
• Establishment, exercise or defence of a legal claim
• Where it is in the vital interest of the data subject or a third party
• The data has been manifestly made public by the data subject

We are a processor of personal data which is collected through open-source research.

Third parties with whom we may share such data include our client who commissioned the work and its advisers who have, themselves, a lawful basis for processing the data. Individuals whose data is processed during the course of our client services have the same rights as all other data subjects and personal data processed in this manner is subject to the same safeguards as set-out in applicable law and above.