Privacy & Cookie Policy

Cupertino Partners Ltd. trading as CEO Partner understands that you care about how the information about you is used and shared. This Privacy Policy explains what information of yours will be collected when you access the site, how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. The use of information collected through our sites shall be limited to the purposes under this Privacy Policy.

Please read our data privacy notice for more information about how we collect, store and process personal data for marketing purposes.

1.     Introduction

1.1.  Your privacy on ceopartner.com.

1.2.  This website is administered by Cupertino Partners Ltd. and is intended to provide you relevant information about our services and the topics of interest to entrepreneurs, start-ups and young businesses.

1.3.  We want you to feel secure when visiting our site and are committed to maintaining your privacy when doing so.

1.4.  The following policy provides an overview of how we protect your privacy during your visit.

1.5.  In this policy, “we”, “us” and “our” refer to Cupertino Partners Ltd.

2.     What information do we gather and how we use it?

2.1.  Information on this website is gathered in two ways:

(a) Indirectly (for example, through the site technology) and

(b) Directly (for example, when you submit information to the website through forms etc.).

In this section we set out the general categories of personal data that we may process, their sources, the purposes for which we may process personal data and the legal basis of processing.

2.2.  Automatically collected usage data – This includes the information that is collected automatically through our Internet access logs. When you access this website, your Internet address is automatically collected and is placed in our Internet access logs. Another way this usage data is collected is through the use of analytics that use cookies. More information about the cookies can be found in Section 9. The automatically collected usage data may include your IP address, browser type and version, operating system, referral source, length of visit, page views, etc.). The usage data may be processed to analyse use of the website, determine what is most effective about our site, identify ways to improve it, and eventually, determine how we can tailor this website to make it more effective. We may also use data for other purposes, which we would describe to you at the point we collect the information. The legal basis for processing this information is the legitimate interest to improve our website services and your consent by using and continuing to use this website. By using and browsing this website, you consent to cookies being used in accordance with our policy. If you do not consent, you must disable cookies or refrain from using the site.

2.3.  User provided data – We also collect information when you voluntarily submit it to us. Throughout our site, we may provide the opportunity to request information, register for an event or seminar or to submit an enquiry through the website. When we collect this type of information, we will notify you as to why we are asking for information and how this information will be used. It is completely up to you whether or not you want to provide it. This data may include your name, email address, company name, phone number, etc. This data may be processed for the purposes of operating our website, providing our services, ensuring security on the website, and communicating with you. The user provided data through the website may also be used for the purposes of offering, marketing and selling relevant services to you. We may also use data for other purposes, which we would describe to you at the point we collect the information. The legal basis for this processing may be your consent at the time of submitting the information, for the performance of a contract between you and us, for taking steps at your request to enter into such a contract, or a legitimate interest.

2.4.  Other data – We may obtain information, including Personal Data, from third parties and sources other than the website, such as advertisers, credit rating agencies, etc. If we combine or associate information from other sources with Personal Data that we collect through the website, we will treat the combined information as Personal Data in accordance with this Policy.

2.5.  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests i.e. the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.6.  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests i.e. the proper protection of our business against risks.

2.7.  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.8.  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.     Will we share this with outside parties?

3.1.  Data we collect will only be used within Cupertino Partners Ltd. We will not directly sell individual information to third parties. Selected data may be shared with our appointed data processor for specific purposes.

3.2.  However we reserve the right to share your relevant personal data with our insurers and/or professional advisers where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also include this information in any sale of the company to a third party.

3.3.  In addition to the specific disclosures of personal data set out in this Section 3, we may share your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.     What about sensitive personal data?

4.1.  We do not generally seek to collect sensitive personal data through this site. If we do seek to collect such data, we will ask you to consent to our proposed uses of the data. We may also collect some sensitive personal data incidentally. By providing us with unsolicited sensitive personal data, you consent to our using the data subject to applicable law as described in this Privacy Policy. The references to ‘sensitive personal data’ are to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent.

5.     What rights do you have?

5.1.  In this Section 5, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of 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 in the specific geography e.g. ICO in the UK.

5.2.  Your principal rights under data protection law are:

a.    the right to be informed

b.    the right to access;

c.     the right to rectification;

d.    the right to erasure;

e.    the right to restrict processing;

f.      the right to object to processing;

g.     the right to data portability;

h.    the right to related automated decision making including profiling

i.      the right to withdraw consent; and

j.      the right to complain to a supervisory authority

Some of the rights are complex, and for more detailed information you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights in the specific geography e.g. ICO in the UK.

5.3.  the right to access to the personal data we hold about you. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data as part of the Subject Access Request (SAR). The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can make the SAR by sending an email to info@cupertinopartners.com. We may need to verify your identity. The SAR enquiries will be dealt within 30 calendar days from the date of enquiry. However, in certain circumstances, we may need to extend that by another 60 days, for which you will be notified in the first 30 days;

5.4.  You may exercise any of your rights in relation to your personal data by written notice to us or by contacting us on info@cupertinopartners.com.

5.5.  If you believe your right to privacy granted by applicable data protection laws has been infringed upon, you have a right to lodge a complaint with data protection authorities.

6.     What about retaining and deleting data

6.1.  This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2.  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3.  We will retain your personal data as follows:

a.     Google Analytics data will be retained for a minimum period of 50 months

6.4.  In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

a.     The legal grounds.

b.    Fulfillment of purpose the data was collected/ processed for

c.     In compliance with any corresponding law(s)

6.5.  Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.     What about data security?

7.1.  We take appropriate steps to maintain the security of your data. We follow generally accepted industry standards to protect information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect your data against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes password protection and other access and authentication controls. We use SSL technology to encrypt data submitted through our website.

7.2.  However, you should understand that the open nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7.3.  If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

7.4.  If you believe your personal data has been compromised or if you have any questions, please contact us on info@cupertinopartners.com.

8.     Will we transfer this information internationally?

8.1.  The data may be transferred internationally by a data processor if its hosted servers are outside the EU. However, in such cases the data processors have put in place relevant safeguards to comply with the EU GDPR.

9.     Cookies

9.1.  Cookies are small files of information that save and retrieve information about your visit to the website – for example, how you entered our site, how you navigated through the site, and what information was of interest to you. This is standard practice on many websites.

9.2.  Cookies can’t harm your computer/handheld device and are active for differing lengths of time; some are stored until you close your browser, while others may last for several weeks or more. By using and browsing this website, you consent to cookies being used in accordance with our policy. If you do not consent, you must disable cookies or refrain from using the site.

9.3.  To find out more about cookies, how they work and how to manage them, visit www.allaboutcookies.org.

9.4.  If you are uncomfortable regarding the use of cookies you can disable cookies on your computer/device by changing the settings in the preferences or options menu in your browser. Use the help facility in your browser application to find out how to disable cookies.

10.  Amendments

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

10.2.   You should check this page occasionally to ensure you are happy with any changes to this policy.

11.  Registered Office Address

11.1.   Cupertino Partners Limited’s registered office address is Profile West Suite 2, Floor 1, 950 Great West Road, Brentford, England, TW8 9ES