Website privacy policy
February 2025
About this notice
1. Fraud Sentinel Ltd (‘we’, ‘our’ or ‘us’) are the controller of Personal Data obtained via our website (www.fraud-sentinel.com), meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2. We take users of our website’s (‘you’ or ‘your’) privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your Personal Data) in connection with your use of our website. It also explains your rights in relation to your Personal Data and how to contact us or a relevant regulator in the event you have a complaint.
3. This privacy policy does not apply to any third-party websites that may have links to our own website.
What do we do with your personal information?
4. We collect, use and are responsible for certain Personal Data about you. When we do so, we are subject to the UK General Data Protection Regulation (“UK GDPR”). We are also subject to the EU General Data Protection Regulation (“EU GDPR”) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (the “EEA”).
5. Given the nature of our website, we do not expect to collect the Personal Data of children. If you are aware that any Personal Data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
6. In this policy:
“Personal Data” means any information relating to an identified or identifiable natural person.
“Special Category Data” is Personal Data that needs more protection because it is sensitive. It means data as follows:
personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
personal data revealing trade union membership;
genetic data;
biometric data (where used for identification purposes);
data concerning health;
data concerning a person’s sex life; and
data concerning a person’s sexual orientation.
What this policy applies to
7. This privacy policy relates to your use of our website only. If you enter into a contract with Fraud Sentinel for the purchase of training products or professional services, this policy will not apply to the provision of those products or services.
8. Throughout our website we may link to other websites owned and operated by our founding companies, Astraea Group Ltd, Learn Interactive Ltd and Parametric Global Consulting Ltd. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their respective privacy policies as appropriate.
Personal data we collect about you
9. The Personal Data we collect about you relates to your use of our website and any messages you submit via the “Contact Us” page or directly by email. We will collect and use the following Personal Data about you:
a) your name, address and contact information, including email address and telephone number and company details;
b) details of any information you provide in the “Subject” and/or “Message” areas of the Contact Us form, or by email;
c) your activities on, and use of, our website;
d) your contact history; and
e) information about how you use our website.
10. We collect and use this Personal Data for the purposes described in the section ‘How and why we use your Personal Data’ below.
How your personal data is collected
11. We collect Personal Data from you:
a) directly, when you enter or send us information, such as when you fill out the Contact Us form on our website, send us an email or register for a webinar or event; and
b ) indirectly, such as your browsing activity while on our website. We will usually collect information indirectly using the technologies explained in the section ‘Cookies’ below.
How and why we use your personal data
12. Under data protection law, we can only use your Personal Data if we have a proper reason, e.g.:
a) you have given consent (where we need your consent, we will ask for it separately from this privacy policy and you can withdraw consent at any time);
b) to comply with our legal and regulatory obligations;
c) to fulfil our contract with you or take steps at your request before entering into a contract (though noting that in those circumstances, privacy will be governed by a separate policy and/or agreement); and/or
d) for our legitimate interests or those of a third party.
13. A “legitimate interest” is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
14. The table below explains what we use your Personal Data for and why.
| What we use your personal data for | Our reasons | |
|---|---|---|
| 15 | Enforcing legal rights or defending or undertaking legal proceedings. | Depending on the circumstances: • to comply with our legal and regulatory obligations; and • in other cases, for our legitimate interests, i.e. to protect our business, interests and rights. |
| 16 | Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website. | Depending on the circumstances: • your consent as gathered by the separate cookies tool on our website—see ‘Cookies [and other tracking technologies]’ below; • where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to potential customers at the best price; • if you have provided such a consent, you may withdraw it at any time by e.g. by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn). |
| 17 | Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended. | Depending on the circumstances: • your consent as gathered [e.g. by the separate cookies tool on our website]—see ‘Cookies [and other tracking technologies]’ below; • where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price; and • if you have provided such a consent, you may withdraw it at any time (this will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn). |
| 18 | Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important notices. | Depending on the circumstances: • to comply with our legal and regulatory obligations; and • in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price. |
| 19 | Protecting the security of systems and data used to provide the services. | To comply with our legal and regulatory obligations: • We may also use your Personal Data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us. |
| 20 | Updating and enhancing client records. | Depending on the circumstances: • to comply with our legal and regulatory obligations; and • for our legitimate interests, e.g. making sure we can keep in touch with our clients about existing and new services. |
| 21 | Statutory returns. | To comply with our legal and regulatory obligations. |
| 22 | Ensuring safe working practices, staff administration and assessments. | Depending on the circumstances: • to comply with our legal and regulatory obligations; and • for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
| 23 | To promote and market our services and those of selected third parties to existing and former clients and third parties including by way procuring goods and services in relation to such promotion and marketing. | Depending on the circumstances: • for our legitimate interests, i.e. to promote our business; and • you have consented. |
| 24 | External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above. | Depending on the circumstances: • for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; and • to comply with our legal and regulatory obligations. |
| 25 | To share your Personal Data with members of our group (as and when there are any) and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency. | In such cases information will be anonymised where possible and only shared where necessary, depending on the circumstances: • to comply with our legal and regulatory obligations; and • in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets. |
| 26 | Statistical analysis to help us manage our business, e.g. in relation to our financial performance, client base, services range or other efficiency measures. | For our legitimate interests, i.e. to be as efficient as can so we can deliver the best service to customers at the best price. |
| 27 | Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations. |
| 28 | The audit of quality check of our products and services (to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above). | For our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. |
29. Where we process Special Category Data, we will also ensure we are permitted to do so under data protection laws, e.g.:
a) we have your explicit consent;
b) the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
c) the processing is necessary to establish, exercise or defend legal claims; and/or
d) the processing is necessary for reasons of substantial public interest.
30. We may use your Personal Data to send you updates (e.g. by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.
31. We have a legitimate interest in using your Personal Data for marketing purposes (see above ‘How and why we use your Personal Data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent.
32. In relation to personal information collected for marketing purposes, the personal information usually consists of:
a) names, contact details, and name of organisation;
b) the nature of your interest in our marketing; and
c) your attendance at any events.
33. This will be processed so that, for example, we can provide you with information about Fraud Sentinel Limited, its founding companies and employees, and to invite you to events hosted by Fraud Sentinel or its founding companies.
34. In all cases, you have the right to opt out of receiving marketing communications at any time by:
a) contacting us using the ‘Contact Details’ below;
b) unsubscribing by email from any marketing emails from Fraud Sentinel Limited, by emailing info@fraud-sentinel.com (subject line ‘unsubscribe’). It may take up to one week for this to become effective; and
c) using the ‘STOP’ number in texts.
35. If you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business, we may ask you to confirm or update your marketing preferences.
36. We will always treat your Personal Data with the utmost respect and we will never sell it to other organisations for marketing purposes.
Who we share your personal data with
37. We may share Personal data with other third parties we use to help us run our business, e.g. marketing agencies, website hosts and website analytics providers.
38. We only allow those organisations to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on them to ensure they can only use your Personal Data to provide services to us and to you.
39. We may share Personal Data with our founding companies Astraea Group Limited, Learn Interactive Limited and Parametric Global Consulting Limited.
40. We only allow our founding companies to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data.
41. We, our founding companies or the third parties mentioned above occasionally also share Personal Data with:
a) our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
b) our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
c) law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
d) other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your Personal Data will be bound by confidentiality obligations
42. If you would like more information about who we share your data with and why, please contact us (see ‘Contact Details’ below).
Transferring your personal data out of the UK [and EEA]
43. This privacy policy is of general application and as such it is not possible to state whether it will be necessary to transfer your information out of the UK or the EEA in any particular case. However, if you reside outside the UK or the EEA then it may be necessary to transfer some of your information to that country outside of the UK or the EEA for that purpose. If you are in a country outside the UK or the EEA or if the instructions you provide come from outside the UK or the EEA then it is inevitable that information will be transferred to those countries. If this applies to you and you wish additional precautions to be taken in respect of your information please indicate this when providing initial instructions.
44. Some countries and organisations outside the UK and the EEA have been assessed by the UK government or the European Commission and their information protection laws and procedures found to show an adequate level of protection of Personal Data (known as an adequacy decision). Most countries do not have the benefit of an adequacy decision. If your information has to be transferred outside the UK or the EEA, then it may not have the same protections and you may not have the same rights as you would within the UK or the EEA. Where we are not required to transfer your Personal Data outside the UK or the EEA, we will only transfer your Personal Data outside the UK and EEA where:
a) the UK government or European Commission has decided that the recipient country benefits from an adequacy decision;
b) there are appropriate safeguards in place (e.g. standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you;
c) a specific exception applies under data protection law;
d) necessary for the conduct of any legal proceedings.
45. You can contact us (see ‘Contact Details” below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of Personal Data when it is transferred abroad.
46. Cloud information storage services based in the USA (who have agreed to comply with the EU-US Data Privacy Framework (DPF) in order to enable us to store your information and/or backup copies of your information) may access your information when they need to. The USA does not have the same information protection laws as the UK and EU but the DPF has been recognised by the European Commission and the UK as providing adequate protection.
47. Cloud information storage services based in Switzerland, in order to enable us to store your information and/or backup copies of your information may access your information when they need to. Switzerland does not have the same information protection laws as the UK and the EU but has been recognised by the UK and the European Commission as providing adequate protection.
48. If you would like any further information, please use the ‘Contact Details’ below at the end of this document.
How long your personal data will be kept
49. We will not keep your Personal Data for longer than we need it for the purpose for which it is used.
50. Names and contact details held for marketing purposes until or unless you inform us that you no longer want us to contact you or ask us to delete your Personal Data. Your Rights
Your Rights
51. You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your Personal Data. |
| Rectification | The right to require us to correct any mistakes in your Personal Data. |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your Personal Data—in certain situations. |
| Restriction of processing | The right to require us to restrict processing of your Personal Data—in certain situations, e.g. if you contest the accuracy of the data. |
| Data portability | The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
| To object | The right to object: • at any time to your Personal Data being processed for direct marketing (including profiling); and • in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for our legitimate interests unless we demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
| The right to withdraw consent | If you have provided us with a consent to use your Personal Data you have a right to withdraw that consent at any time. You may withdraw consents by emailing us using the “Contact Details” below. Withdrawing consent will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn. |
52. If you want more information about your rights under the UK GDPR, please see the Guidance from the Information Commissioners Office on Individual’s rights under the UK GDPR.
53. If you want to exercise any of these rights, please:
contact us using the ‘Contact Details’ below;
provide enough information to identify yourself (e.g. your full name, address and client or matter reference number) and any additional identity information we may reasonably request from you; and
let us know what right you want to exercise and the information to which your request relates.
54. We will respond to you within one month from when we receive your request.
Cookies
55. Cookies are small pieces of data which are stored for you on your computer by your web browser. Their purpose is to improve your online experience and they are used by almost every website.
56. We aim to keep cookies to a minimum, and we only use the following cookies:
57. Google Analytics: these cookies are called __utma __utmb __utmc and __utmz. We use Google’s cookies to collect information about how visitors use our site and we use that information to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, from where visitors have come to the site and the pages they visited. You can find further information here: https://policies.google.com/technologies/types.
58. Social Sharing & Add This: these cookies are called __atuvc and __atuvs; loc, mus, ouid uid, uvc and xtc. These cookies allow the user to share content via their own social channels. You can find further information here: https://cookiepedia.co.uk/cookies/__atuvc.
59. LinkedIn: these cookies are called lidc. These cookies allow the user to share content via LinkedIn. You can find further information here: https://www.linkedin.com/legal/cookie-table.
60. If you are not happy with the cookies that we use, you should either not use our website, or you should delete cookies after having visited the site. Alternatively, you should browse our website using your browser’s anonymous usage setting.
Keeping your Personal Data secure
61. We have implemented appropriate technical and organisational measures to keep your Personal Data confidential and secure from unauthorised access, use and disclosure. We limit access to your Personal Data to those who have a genuine business need to access it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.
62. We require our business partners, suppliers and other third parties to implement appropriate security measures to protect Personal Data from unauthorised access, use and disclosure.
63. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.
How to make a complaint
64. Please contact us if you have any queries or concerns about our use of your Personal Data (see below ‘Contact Details’). We hope we will be able to resolve any issues you may have.
65. The UK GDPR gives you the right to lodge a complaint with the Information Commissioners’ Office if you are in the UK or under the EU GDPR with the supervisory authority of the relevant Member State/EEA member country. You may be able to lodge a complaint with another relevant supervisory authority in your jurisdiction or other jurisdiction where you work, normally live or where the alleged infringement of data protection laws occurred. The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/
Future Processing
66. We do not intend to process your personal information except for the reasons stated within this privacy policy. If this changes, this privacy policy will be amended and placed on our website.
Updating your Personal Data
67. We take reasonable steps to ensure your Personal Data remains accurate and up to date. To help us with this, please let us know if any of the Personal Data you have provided to us has changed, e.g. your surname or address—see below ‘Contact Details’.
Changes to this privacy policy
68. We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by informing the data subject of changes to the policy, e.g. by including a prominent link to a description of those changes on our website for a reasonable period of time.
Do you need extra help?
69. If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘Contact Details’ below).
Contact Details
70. If you have any questions about this privacy policy or the information Fraud Sentinel Limited holds about you or you wish to exercise a right under data protection law or to make a complaint, please contact:
Nina Stewart
7 Down Street, London, W1J 7AJ
T 020 3875 9057
M 07931 388932