Last updated: 15th August 2023
What does this policy cover?
This policy describes how Walr Group Limited (also referred to as “Walr”, “we” or “us”) will make use of your data when you use our website (https://walr.com/) (“website”) or platforms (“Platform”), respond to surveys or purchase products or services from us.
It also describes your data protection rights, including a right to object to some of the processing which Walr carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
What information do we collect?
We collect personal data about:
- our current and prospective customers and their staff and employees;
- our service providers and business partners and their staff and employees;
- individuals who attend, or express interest in attending, our events;
- respondents to Walr surveys; and
- visitors to our website and Platform users.
We collect and process personal data about you when you interact with us and our website and Platforms, and when you purchase goods and services from us. This includes:
- identity and contact details, including your name, email address, address, contact number;
- payment details, including billing addresses, bank account numbers and sort codes, and card details, where you make purchases from us or where we make payments to you;
- communication information, including metadata, received via emails, instant messages and calls you make to us;
- respondent information, including responses to survey questions, national insurance, social security or other national ID number information, passport, driving licence or other ID card information;
- sensitive information, including personal data revealing religious or philosophical beliefs, personal data revealing racial or ethnic origin, personal data revealing political opinions, 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, data concerning a person’s sexual orientation, criminal activity data;
- technical information, including information related to the browser type or version and device type you use to access our website, your IP address, login data, location information, network; and
We receive information from other sources, such as our customers who send surveys to you on our platforms. Where agreed with our customers and with your consent, we use this information for our analytics purposes and to provide improved services.
Providing personal data is optional; however, in order to provide you with access to our Platform and services, providing certain personal information (e.g., contact information and name) may be necessary in order to receive our services and use our Platforms.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you wish to participate in a panel or purchase our goods or services. This includes:
- verifying your identity;
- making or taking payments;
- communicating with you;
- providing customer services and arranging the delivery or other provision of products or services;
To do this, we will use your identity and contact details, payment details, communication details and respondent details.
- As required by Walr to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to provide Platforms, products and services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of our Platforms, websites and online services, and use your information to help us monitor, improve, troubleshoot and protect our Platforms, products, content, services and website, both online and offline;
- we use information you provide to recommend features, Platforms, products, and services that might be of interest to you, identify your preferences, personalise your experience with Walr, including our website, products or services;
- we monitor customer and respondent accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- we use data of some individuals to invite them to take part in customer satisfaction surveys;
To do this, we will use your identity and contact details, payment details, communication details and respondent details.
If you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud.
- Where you give us consent:
- we will send you direct marketing in relation to our relevant products and services;
- we will build your respondent profile and send you panel requests based on your respondent profile;
- we will use your personal information to display interest-based ads for features, products, and services that might be of interest to you;
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
To do this, we will use your identity and contact details, technical information, respondent details and communication details.
- For purposes which are required by law:
- in response to requests by government or law enforcement authorities conducting an investigation.
What are cookies?
We also use other forms of technology which serve a similar purpose to cookies and which allow us to monitor and improve our website. When we talk about cookies, this term includes these similar technologies.
What cookies do we use and what information to they collect?
- Necessary cookies: these cookies are required to enable core functionality. Without these cookies, services you have asked for cannot be provided. If you disable these cookies certain parts of the Services will not function for you.
- Analytics cookies: these cookies help us improve or optimise the experience we provide. They allow us to measure how visitors interact with the Services and we use this information to improve the user experience and performance of our website and the Services. These cookies are used to collect technical information such as the number of pages visited, which parts of our website are clicked on and the length of time between clicks.
- Advertising cookies: we use these cookies to collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. We may share this information with other parties who help manage online advertising – please see the “Third parties” section below for more details.
- Social media cookies: These cookies are used when you share information using a social media sharing button or “like” button on our Platforms, or when you engage with our content on or through a social site such as LinkedIn or Facebook. These cookies collect information about your social media interaction with the website, such as whether or not you have an account with the social media site and whether you are logged into it when you interact with content on the website. This information may be linked to targeting/advertising activities.
Finally, we may use web beacons or similar technologies from third-party analytics providers (like, for example, Google Analytics) that help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products.
|Purpose||Third party||Retention Period|
|To understand how visitors engage with the Walr website.||Google Analytics||2 years|
|To understand how visitors engage with the Walr website.||HubSpot||6 months|
|To understand the success of potential advertising campaigns.||90 days|
Who will we share this data with, where and when?
We will share your personal data with other Walr group companies to help provide you with products and services and support our administration.
Personal data may be shared with auditors, regulators, government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of Walr for the purposes identified above. Such third parties include providers of website hosting and maintenance, payment providers, call centre operators.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Transfers outside of the EEA and UK
Where information is transferred outside the EEA and UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or under the UK government adequacy regulations or considered adequate as determined by applicable data protection laws, we take steps to ensure your personal data is adequately protected. This includes using the EU Commission approved standard contractual clauses, the UK Information Commissioner approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules.
Security of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
You have various rights with respect to our use of your personal data:
- Access: You have the right to request a copy of the personal data that we hold about you. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up to date.
- Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us.
- Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
- Erasure: You have the right to ask us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts. This is likely to be the Information Commissioner’s Office in the UK.
To exercise any of these rights, you can get in touch with us using the details set out below.
For the purchase of our goods and services the provision of information is mandatory: if relevant data is not provided, then we will not be able to accept your offer to purchase goods or services. All other provision of your information is optional, but this may affect your experience of our goods and services.
Right to withdraw consent
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
How long we keep your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
Updates to this privacy notice
We reserve the right to update and change this notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our notice.
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at email@example.com or by writing to 18 Crucifix Lane, London, SE1 3JW.