Compliance
Compliance Policy

Third Bridge Privacy Policy

1 Background

Third Bridge Group Limited is a company registered in England and Wales (company number 06263699).

Third Bridge, together with the other members of its group (“we/us/our”), are committed to safeguarding the privacy of third parties with whom we interact, including our clients, third parties who visit our websites (“websites”) and/or to who we provide services to or otherwise engage with (“you/your”).

This Privacy Policy sets out our personal information collection and sharing practices for our websites and through the other channels described below. If you use our websites or provide your information to us (either via this website, in person, over the phone or by email (or by other means of electronic communication)), you agree to the processing set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your personal information, together with the ability to opt in or out of selected uses may also be provided to you when we collect personal information from you.

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the “Data Protection Legislation” which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”), the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), the UK Data Protection Act 2018, the California Privacy Rights Act of 2020 the Personal Information Protection Law (“PIPL”) in China, and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it.

By using or accessing our websites or the services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

(a) What personal information about you we may collect

(b) How we may use your personal information

(c) Who we may disclose your personal information to

(d) How we protect your personal information

(e) Contacting us & your rights to prevent marketing and to access and update your personal information

(f) Our Cookies Policy

(g) Your Right to make a Complaint

(h) How changes to this Privacy Policy will be made

2 Information we may collect about you

Generally

2.1  We may collect personal information about you from the following sources:

(a)  Our correspondence: if you contact us by post, telephone, live chat, email or other electronic means we may keep a record of that correspondence;

(b)  Information you provide to us: personal information that you provide to us, such as during the registration process to access and use the websites or otherwise interact with us, including your name (pinyin), title, position, contact details, username or similar identifier;

(c)  Your transactions: details of transactions you carry out through our websites or through other channels and of the fulfilment of the services we provide;

(d) Website and communication usage: details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access; and

(e)  Survey information: we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey.

2.2  We may also collect the following personal data:

(a) Profile data including your username and password, reservations made by you, your interests, preferences, feedback and survey responses;

(b) Usage data including information about how you use our Website and Services;

(c) Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences;

(d) Cookies Data – we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to ‘Cookies’ in section 7 below for information about cookies and how we use them and what kind; and

(e) Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the websites, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our websites and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the websites, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please also refer to section 7.2 of this Privacy Policy.

Specialists

2.3  Third Bridge is a primary research company and part of our business activities involve the identification of industry experts (“Specialists”) and the introduction of them to our clients, for the purposes of consultations and other interactions and the publishing of transcripts and recordings of interviews on our content portal (“Engagements”), to assist our clients in making informed investment decisions.

We may collect and process the following personal information about you if you are a Specialist:

(a) Information we may collect on you: we may collect information about you which may include your name (pinyin), academic and professional background and employment history, including the identities of your current and former employers and job titles/positions, from publicly available sources such as information that can be found using search engines, on corporate websites and information which you have clearly decided to make public (such as information you have made available on business networking platforms and social media); and

(b) Information you provide to us: personal information that you provide to us including your name (pinyin), address, telephone numbers, email address(es) and other contact details, detailed information in respect of your academic and professional background and employment history (and other information typically contained in a detailed CV/resume).

If you participate in an Engagement through us we may request your bank account details to be able to make payment to you. We may also be required to perform a background check on you in accordance with our compliance policies. You consent to us performing such checks in order for us to adhere to industry best practices, to ensure that your identity and financial data is a match in order to prevent fraud, to check that you are not on a sanctions, regulatory or law enforcement list or have a criminal record and that you pass negative media screening.

Clients and Prospective Clients

2.4 Service provision data: if you are a client (or a prospective client), in addition to the information referred to in paragraph 2.1, we may collect personal information on you in the ordinary course of our business relationship with you i.e. the provision of our services to you.

PRC Specialists and Clients (or Prospective Clients)

2.5 If you are a user (Specialist or client (or a prospective client)) located in the People’s Republic of China (“PRC”), please note that we may collect your personal and/or sensitive information including, but not limited to, the information provided in Clause 2.1(a), 2.1(c), 2.1(d) and 2.2(c). Engagements and/or payments cannot be completed without your consent for us to collect your personal information.

3 Uses made of your personal information

We may use your personal information in the following ways. For each use, we note the grounds we use to justify each use of your personal information – please see paragraph 3.5 for a more detailed explanation of these grounds.

3.1 Generally

(a)  For research and development purposes: to analyse it in order to better understand your and our client’ service requirements, to better understand our business and develop our products and services.

Use justification: legitimate interests (to allow us to improve our services).

(b)  To record and monitor certain activities: to record and monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud.

Use justifications: legal obligations, legal claims, legitimate interests (to ensure the quality and legality of our services).

(c) To inform you of changes: to notify you about changes to our services and products.

Use justification: contract performance (to notify you about changes to our service).

(d)  To ensure website content is relevant: to ensure that content from our websites is presented in the most effective manner for you and for your device.

Use justification: consent, contract performance, legitimate interests (to allow us to provide you with the content and services on the websites).

(e)  To reorganise or make changes to our business: In the event that we are: (i) subject to negotiations for the sale of our business or part thereof to a third party; (ii) sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer it to that re-organised entity or third party and use it for the same purposes as set out in this policy or for the purpose of analysing any proposed sale or re-organisation.

Use justification: Contract performance, legal obligations (in order to allow us to change our business).

(f)  In connection with legal or regulatory obligations: Law enforcement, regulators and the court service. We may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. If you are a Specialist, we may also perform a background check on you to comply with our compliance processes including to prevent fraud, bribery, corruption and sanctions breaches.

Use justification: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).

3.2 Specialists

If you are a Specialist:

(a)  To provide our services effectively to our clients: we gather the personal information described above in order to be able to identify Specialists and to introduce them to our clients. We use and analyse the information which we collect about you in order to identify Engagements which may be within your field of expertise and of interest to you. We may disclose the following personal information about you to clients who may wish to consult with you through Engagements: your biographical information, information in respect of the number of times you have previously consulted with our clients and/or information in respect of feedback received in respect of those consultations. We may provide prospective clients with your biographical information for the purposes of demonstrating the quality and coverage of our Specialist network. We may provide your contact details to clients with which you have agreed to take part in an Engagement including, but not limited to your email address, phone number and other electronic communication contact details. Should you agree to take part in an interview which may be recorded or transcribed for our content portal, you consent to us displaying your name and biographical information on our content portal in order to attribute that content to you.

Use justification: consent; legitimate interests.

(b)  To ensure that you are paid: to ensure that you are paid for the services which you have provided.

Use justification: contract performance, legal claims, legitimate interests.

3.3 Clients and Prospective Clients

If you are a Client or a prospective client:

(a) To provide our services effectively to you and conduct our business: to administer our services, including to carry out our obligations arising from any agreements entered into between you and us, to prevent any unauthorised access by implementation of proper authentication method (e.g Multi-factor Authentication (MFA) via text message or email) , which may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors); identifying the most suitable Specialists for Engagements with you and identifying other products and services which may be of interest to you.

Use justification: consent, contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you).

b) To ensure that we are paid: to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings).

Use justification: contract performance, legal claims, legitimate interests (to ensure that we are paid for our services).

3.4 Clients, Prospective Clients and Specialists: To provide you with marketing materials

To provide you with updates, where you have chosen to receive these. We may also use your information for marketing our products and services to you by post, email, phone (including text) and other electronic means and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in paragraph 6.7 below.

Use justification: consent, legitimate interests

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at dpo@thirdbridge.com and we will either delete your data from our systems or move your data to our “unsubscribe list’. However, you acknowledge this will limit our ability to provide the best possible services to you.

As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email, telephone, text or other electronic communication with information, news and offers on our services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Legislation.

3.5  Legal justifications for use of personal information

Use of personal information under Data Protection Legislation must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this Privacy Policy. An explanation of the scope of the grounds available can be found below. We note the grounds we use to justify each use of your information next to the use in paragraphs 3.1 to 3.4 above.

  • Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use).
  • Contract performance: where your information is necessary to enter into or perform our contract with you.
  • Legal obligation: where we need to use your information to comply with our legal obligations.
  • Legitimate interests: where we have a legitimate interest in using your data and our reasons for using it and this is not outweighed by any adverse impact on your interests, fundamental rights or freedoms.
  • Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

4 Transmission, storage and security of your personal information

Security over the internet

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our websites. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

4.1  No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with Data Protection Legislation requirements. In any event, you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

4.2  All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

4.3 If you communicate with any third party through our service, please take necessary consideration when you decide to provide your personal information to the third party, including, but not limited, your contact information or address. Please keep your personal information safe and only provide your personal information to a third party when it is necessary.

4.4 Any payments made by you, will be encrypted.

Export outside the EEA or UK

4.5  If you are a user in the UK or EEA, note that because our business is international we may need to transfer your personal information to third parties and also to other members of the Third Bridge group. Your data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) or UK in which data protection laws may be of a lower standard than in the EEA or UK.

If we do store or transfer data outside the UK or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR or in the EEA under GDPR (as the case may be).

Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In respect of other countries we will transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities (or if the information (limited to information specified in paragraph 2.2(a)) is already publicly accessible there). Please contact us as set out in paragraph 6.7 below if you would like to see a copy of the specific safeguards applied to the export of your personal information.

Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK and/or EEA if it is necessary for us to do so.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Export outside the PRC

4.6 If you are a user in the PRC, given the business is global, please note that we may need to transfer your personal information to third parties and affiliates of Third Bridge outside of the PRC. We will comply with Data Protection Legislation in relation to such exportation.

Storage limits

4.7  We will retain your personal information for as long as is necessary for the processing purpose(s) for which they were collected and any other permitted linked purpose (for example certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So, if information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

4.8  We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either anonymised (and the anonymised information may be retained) or securely destroyed.

5. Disclosure of Information 

5.1 We are allowed to disclose your information in the following cases:

5.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer;

5.1.2 We can disclose it to other businesses in our group;

5.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights;

5.1.4 We can exchange information with others to protect against fraud, money laundering, bribery, insider trading or credit risks.

5.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, background checks, advertising and marketing. In some cases, the third parties may require access to some or all of your personal information that we hold. The details of these third parties may be provided to you on written request to our contact details listed in clause 6.7 below.

5.3 If you are a Specialist, by registering and agreeing to this Privacy Policy, you consent to Third Bridge sharing your employment history and details of your current occupation/role with our clients in relation to proposed Engagements. Should you agree to participate in a consultation with a client, you consent to us sharing your name and contact details (including phone number, email address and other electronic contact details) with that client for the purposes of your participation in that consultation. The details of any clients to which we have provided your personal information may be provided to you on written request to our contact details listed in clause 6.7 below. Should you consent to participate in an interview which will be uploaded to our content portal, you consent to us displaying your name, current occupation/role and employment history alongside the transcript/recording. You acknowledge that our content portal may be accessed by all our clients globally who have licensed access. Our clients will all have contractually agreed not to share, distribute or otherwise provide access to that content to anyone who is not a licensed user. However, we do not guarantee their compliance with that contractual obligation. We may also publish your name and biographical information publicly in connection with content based on transcripts or recordings of interviews with you, but only with your specific written consent.

5.4 Where any of your data is required to be shared with a third party, we will take reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under Data Protection Legislation. Any third party that we share data with will not be permitted to use it for any other purpose than in connection with their contract with us.

6 Your rights & contacting us

Marketing

6.1  You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out in paragraph 6.7 below.

Your rights

6.2  If you have any questions in relation to our use of your personal information, you should contact us as per paragraph 6.7 below. Under Data Privacy Legislation, under certain conditions, you may have the right to require us to:

(a)  provide you with further details on the way we use your personal information;

(b)  provide you with a copy of personal information that you have provided to us;

(c)  update any inaccuracies in the personal information we hold (please see paragraph 6.7);

(d)  delete any personal information the we no longer have a lawful ground to use;

(e) where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 5.1 for marketing);

(f) object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

(g) restrict how we use your information whilst a complaint is being investigated; and

(h) deactivate your account.

6.3 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

6.4 Should you wish to exercise any of your data subject rights listed above at clause 6.2, please submit a request using our Webform found here. Please note that we may need to verify your identity in order to action your request.

6.5 If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office.

Updating information

6.6 We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in paragraph 6.7 below.

Contacting us

6.7 If you have any questions in relation to this policy, please contact our Data Protection Officer by email to: dpo@thirdbridge.com.

7. Cookies policy

7.1  We use cookies to help us understand user behaviour. The cookies are stored on a user’s web browser and they let us know a user’s activities on our website. We analyse users’ behaviour in order to better serve the users and to make improvements to our website.

7.2  We do not collect any personally identifiable information from the user unless the information is explicitly provided to us by the user through submission forms on our website. We do not sell any personally identifiable information to any third parties. We use Google Analytics to keep track of our website traffic, which may use cookies for this purpose. Please refer to Google Analytics’ privacy policy for further information.

8. Your Right to make a Complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

9. Changes to our Privacy Policy 

We may change the content of our websites and how we use cookies without notice, and consequently our Privacy Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website from time to time to stay informed of how we are using personal information.

10. Your agreement

By using our websites and by way of acknowledgment, you agree to our Privacy Policy.

11. Dispute Resolution

11.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

11.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.

11.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided

This Privacy Policy was last updated on November 2022.