RIGHTSPEND

Privacy Policy

Introduction

We, Columbus Holdings UK Limited, trading as Rightspend, take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws such as the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

This privacy notice aims to give you information on how Rightspend collects and processes your personal data through your use of our website and any data you may provide if you contact or engage with us regarding our products and services.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us on [email protected]

Lawful Basis of Processing Personal Information

We only collect and use personal information about you when the law allows us to. We have successfully identified our lawful basis for processing across the business and we use the following:

  • The data subject (you) has given consent to the processing activity taking place.
  • If the processing is necessary for the performance of a contract
  • If the processing is necessary for compliance with a legal obligation to which the controller is subject
  • If the processing is necessary for the purpose of the legitimate interest by us or our partners.
  • Where we may rely on consent

We may like to use your personal data for a variety of different purposes and in that case, we will obtain your prior consent before we do so.

The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way, including where we are using the information for performance of a contract with you or pursuant to our legitimate interest.

You may at any time withdraw the specific consent you give to our processing your personal data.

Please note even if you withdraw consent for us to use your personal data for a particular purpose, we may continue to rely on other bases to process your personal data for other purposes.

If you have any questions regarding our lawful basis for processing your data, please get in contact: [email protected].

Contractual or Statutory requirements on you to provide personal data

In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter a contract.

It is your choice as to whether you provide us with your personal data necessary to enter a contract or as part of a contractual requirement. If you do not provide your personal data, then the consequences of failing to provide your personal data are that we may not be able to perform our service to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so, and that information is incorrect.

Who you are

The types of personal data we process, our purpose, and the lawful basis for processing as well as how we make use of the data, depends upon the relationship you have with us.

In the sections that follow we have outlined the type of personal data we collect and how we collect it, the purposes for which we process personal data and our lawful bases for our different relationships. Please select the relevant section for you from the list below, based on the relationship you have with us:

  • Website Visitors
  • Clients / Customers and Their Employees
  • Suppliers and Their Employees
  • Our Employee Candidates (Recruitment)

Please note that the examples above are not intended to be exhaustive and represent a description of the kinds of sources of information we rely upon. If you have any questions that the above does not answer, please get in touch and we will be happy to help.

WEBSITE VISITORS

Why we collect your personal information

  • For operational purposes such as operating our website and ensuring it is presented in the most effective manner for you and for your computer or device
  • For the purpose of managing our relationships, communicating with you by email, post, and/or telephone, providing support services and complaint handling including to process your enquiries
  • For providing you with information you have requested from us via our web enquiry form, to discuss your enquiry
  • Where you have consented to be contacted for such purposes, for the purposes of creating, targeting and sending direct marketing communications by email, post and/or making contact by telephone for marketing-related purposes to provide you with information, resources or services that you request from us or which we feel may interest you
  • For the purpose of researching and analysing the use of our websites and services
  • For the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally
  • For ensuring the safe operation and monitoring the performance of our website
  • For notifying you about changes to our service

We only collect and use personal information about you when the law allows us to. Most commonly, we use it if the processing is necessary for the purpose of the legitimate interest pursed by us or our partners.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

  • The purpose test – to identify the legitimate interest
  • Necessity test – to consider if the processing is necessary for the purpose identified
  • Balancing test – considering the individual’s interests, rights, or freedoms and whether these override the legitimate interests identified.

What information we collect and where from

We collect personal information from you, when you interact with our websites under the under the domain https://rightspend.com

The categories of personal information that we may collect, store, and use about you include:

  • Information about your activity on our site including
  • Information that you provide by filling in forms on our website, this includes information provided at the time of registering to use our site, subscribing to receive information, or requesting further services.
  • We may also ask you for information when you report a problem with our site.
  • Records of your correspondence with us
  • Company Name and job title
  • Contact information such as email addresses, postal address & telephone numbers

CLIENTS/CUSTOMERS AND THEIR EMPLOYEES

Why we collect your personal information

  • For the purpose of looking for new prospects
  • For the purpose of managing sales processes
  • To enable the arrangement and fulfilment of the contract of services between us
  • For the purpose of managing our relationships, account development, communicating with you, providing support services and complaint handling including to process your enquiries
  • For the purposes of creating, targeting, and sending direct marketing communications or to provide you with information, resources, or services that you request from us or which we feel may interest you, for running a campaign if we feel your organisation might benefit from our services
  • For the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

  • The data subject (you) has given consent to the processing activity taking place
  • If the processing is necessary for the performance of a contract
  • If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners

What information we collect and where from

We collect personal information from you, through publicly available resources, referrals or directly from you when you interact with our websites under the under the domainhttps://rightspend.com/ or enquire about any of our services. The categories of personal information that we may collect, store, and use about you include:

  • Name, email address, telephone numbers
  • Business information containing names of key stakeholders within the business
  • Records of your correspondence with us including email records
  • Company Name and job title

When we are providing our services to Clients, we will also act as a data processor for personal data for the provision of training to Client employees, management of Client stakeholders, creating materials and distribution lists and sending out surveys.

Personal data collected from third parties

We may obtain personal data about Individuals from third-party organisations that provide business contact details (which collect personal data as data controllers in their own right from publicly available sources). This personal data is transferred to us as an independent controller. When we receive your personal data, we use it as set out in this privacy policy and in particular to contact you for marketing purposes. This personal data consists of your name and business contact details.

SUPPLIERS AND THEIR EMPLOYEES

Why we collect your personal information

  • For the issuing and tracking and invoices and where we need to perform the contract that we have entered with you such as by making payments
  • For the purpose of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing)
  • For the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally

We only collect and use personal information about you when the law allows us to. Most commonly, we use it:

  • If the processing is necessary for compliance with a legal obligation to which the controller is subject.
  • If the processing is necessary for the performance of a contract

What information we collect and where from

We collect your personal data when you or your employer enters a relationship with us. We may collect and process the following information about you:

  • Identification information such as name and surname
  • Contact information such as email, telephone number
  • Job Title
  • Company address
  • VAT, bank details, payment information

OUR EMPLOYEE CANDIDATES (Recruitment)

Why we collect your personal information

  • For the purpose of carrying out our recruitment process and determine eligibility for the advertised role and your suitability to work with us
  • For the purpose of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, post, and/or telephone, providing support services and complaint handling

We only collect and use personal information about you when the law allows us to. Most commonly, we use it:

  • If the processing is necessary for compliance with a legal obligation to which the controller is subject.
  • If the processing is necessary for the performance of a contract.

As well as collecting information from you we may also collect it from other sources including any professional profiles online (such as LinkedIn) and your professional referees such as former managers. We use all data sources lawfully and we only collect types of data relevant to our recruitment needs. We do not process irrelevant data (such as cultural information) for recruiting purposes.

We may collect and process the following information about you:

  • Identification information such as name and surname including any other listed on the CVs such as nationality
  • Information available on CV or cover letters
  • Contact information such as email addresses, postal address & telephone numbers
  • Education history such as establishments attended and qualifications.
  • Employment history
  • Professional references from referees you provide
  • Proof of right to work in the UK
  • If you give your explicit consent, information on any disability you may have for which we need to make reasonable adjustments during the recruitment process.

Where your job application with RightSpend is unsuccessful, we will delete your personal data after six months following the end of campaign. If we would like to consider you for future roles, with your consent we will hold your data for an additional six months. After one year, if you and RightSpend wish to continue to keep in touch for recruitment purposes, we will ask for your consent to continue storing your data for a further year.

GENERAL

Personal data about other people which you provide to us

If you provide personal data to us about someone else, you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

How long do we keep information for?

We will store your personal data for the time that we believe is appropriate in accordance with our data retention policy.

We keep the length of time that we hold personal data under constant review. Those reviews take place annually. If you have any questions regarding the retention of your data, please get in touch.

Accuracy of your personal information

It is important that the personal data we hold about you is accurate and current, and we take all reasonable precautions to ensure that this is the case, but we do not undertake to check or verify the accuracy of personal data provided by you.

Please keep us informed if your personal data changes during your relationship with us by contacting us either via your Rightspend account manager or using [email protected].

We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us or permit us to retain through failing to notify of any changes to your personal information.

Security of personal information

Rightspend is committed to handling your personal information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their job responsibilities.

At Rightspend we have also ensured that all employees have enough information security training and have a set of data protection policies which helps maintain, enforce, and communicate best practices throughout the business.

Children’s information

Rightspend does not knowingly collect information on children without consent from a responsible parent. If you are aware that RightSpend have inadvertently collected personal information on a child, please inform us immediately, so we can either remove this or see the appropriate consent information without any undue delay.

Your individual rights

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Please note, not all of these rights are absolute and there are scenarios where your rights may be refused under the appropriate exemptions laid out by the ICO.

Your principal rights under General Data Protection Regulation are:

  • The right to be informed (through this notice)
  • Right to Access
  • Right to Rectification
  • Right to Erasure
  • Right to Restrict Processing
  • Right to Object
  • Right to Data Portability

Right to Contest Automated Decision Making (Automated decision making is not carried out by Rightspend)

You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You, as a data subject, have the right to rectification, which will allow you as the data subject to modify/change any personal information to the purpose of ensuring that the information we process is update to date.

The right to erasure or right to be forgotten will allow you as the data subject to inform us that you no longer want Rightspend to continually to store or process your personal information. Please be aware that we may decline your right for several reasons, which are not limited to, having a lawful basis to process your information or us needing your information for the performance of a contractual obligation.

As a data subject, you have the right to stop any processing of your personal information. Please be aware that you must provide us with a legitimate reason for us to stop processing. Any request made that does not conform to the GDPR will be rejected.

On occurrence Rightspend may send you marketing emails to make you aware on new products that we believe can benefit you, the data subject and in situations where you have consented to this activity. As you have the right to object, you can click the unsubscribe link on all our emails to inform us that you no longer want to receive marketing emails from us.

The right to data portability will allow you as the data subject to have your personal information securely transferred to another organisation for processing. At Rightspend we place this reasonability on you that data subject. When you make this request, we will export all information about you and securely transfer it to yourself. You, the data subject will be able to give this information to your chosen organisation.

If you have any question about these rights, please see “additional information” section of this policy.

International Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). By submitting your personal data to us, you agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Right to complain

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email on [email protected]

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Website: Click Here
By Email: [email protected]
By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)

Additional information

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our Compliance Team via email on [email protected]

Review of this Policy

We keep this Policy under regular review. This Policy was last updated on 10 March 2025

Amendments

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.