The small print
PRIVACY NOTICE
1. Who We Are
This Privacy Notice applies to Compliance and Operations, RivkaAbecasis.com, operated by Polaris Partners Ltd ("Polaris Partners", "we", "us" or "our").
Polaris Partners Ltd is the legal entity responsible for the Rivka Abecasis brand and website.
Registered office:
Churchill House
137–139 Brent Street
London
NW4 4DJ
ICO registration number: ZC051061
For privacy and data-protection enquiries, please contact:
info@rivkaabecasis.com
Rivka Abecasis is responsible for data protection and privacy matters on behalf of Polaris Partners Ltd. Polaris Partners Ltd has considered whether it is required to appoint a statutory Data Protection Officer and does not currently consider that it meets the criteria requiring a formal DPO appointment.
2. What This Notice Covers
This Privacy Notice explains how Polaris Partners Ltd collects, uses, stores and protects personal data in connection with RivkaAbecasis.com , RivkaAbecasis.com & ComplianceandOperations.com and related business enquiries and communications.
The website is primarily a professional portfolio and information website. A visitor does not become a client simply by visiting the website, submitting an enquiry or booking a Discovery Call. A client relationship is established only following appropriate discussions and agreement of the relevant contractual terms.
Where we process personal data on behalf of a client as part of a professional engagement, we may act as a data processor rather than as a controller. That processing will be governed by the applicable contract, scope of work, Data Processing Agreement and the client's documented instructions.
3. Personal Data We Collect
Depending on how you interact with us, we may collect the following information:
- Name
- Email address
- Telephone number
- Company name
- Company website
- Job title
- Nature and purpose of your enquiry
- Information you provide when communicating with us
- Information provided when booking a Discovery Call, including meeting purpose, questions or comments
- Business and professional information necessary to manage a prospective or existing business relationship
- Information contained in correspondence and business records
We do not intentionally request special category data, criminal offence data or other sensitive personal information through the website. Please do not submit such information through a website enquiry or booking facility unless we specifically ask you to do so.
4. Website Enquiries
If you contact us using the contact details provided on RivkaAbecasis.com or RivkaAbecasis.com & ComplianceandOperations.com, we will process the information you provide so that we can respond to your enquiry, understand the nature of your requirements and, where appropriate, discuss whether our services may be suitable.
Lawful basis: our legitimate interests in responding to a business enquiry and developing potential professional relationships, balanced against your rights and interests.
If a website enquiry form is introduced, the information collected will be limited to what is reasonably necessary for the enquiry, such as name, email address, telephone number, company, website and nature of enquiry.
5. Discovery Calls and Calendly
We use Calendly as a third-party scheduling platform to arrange initial business conversations and free Discovery Calls.
When you book a Discovery Call, Calendly may collect information such as your name, email address, telephone number, company, job title, meeting purpose, questions or comments and any other information you voluntarily provide through the booking form.
Calendly may connect with our Google Calendar and Google Meet environment to facilitate scheduling and the meeting.
Booking a Discovery Call does not create a client relationship or constitute an agreement to provide services.
6. Google Workspace
We use a dedicated Google Workspace business environment associated with RivkaAbecasis.com for business email, document storage, calendars, meetings and related business administration.
Google Workspace may therefore contain personal data relating to prospects, clients, suppliers, professional contacts and other individuals with whom we communicate.
Access to business information is restricted to authorised users and service providers where necessary for legitimate business purposes and subject to appropriate contractual and confidentiality arrangements.
7. HubSpot
We use HubSpot as a customer relationship management system for internal business administration. It may be used to store information relating to prospective and existing clients, business contacts and relevant forms or CRM records.
At the date of this Privacy Notice, HubSpot is not connected to RivkaAbecasis.com, RivkaAbecasis.com & ComplianceandOperations.com for website visitor tracking and we do not use HubSpot tracking code on the website.
HubSpot may be used to manage information after an enquiry or prospective business relationship has been established.
8. LinkedIn and Other External Websites
RivkaAbecasis.com may contain a link to Rivka Abecasis's LinkedIn profile. The LinkedIn profile is linked externally and is not embedded into the website.
When you follow an external link, the third party's own privacy notice and terms apply. We do not control the privacy practices of external websites or platforms.
9. Cookies and Similar Technologies
The website is currently a simple portfolio/landing-page website built using Google Sites. We have not intentionally added Google Analytics, advertising pixels, HubSpot tracking or other behavioural tracking technologies.
Google Sites and associated technical services may nevertheless use cookies or similar technologies necessary for the operation, security and functionality of the website.
A separate Cookie Policy will explain the cookies and similar technologies actually used on the website and, where required, the consent choices available to visitors.
We will review the website's cookie and tracking configuration when functionality changes and will update the Cookie Policy and consent mechanism where necessary.
10. AI-Assisted Tools
We use technology and AI-assisted tools as part of our business operations and, where appropriate, in delivering professional services. Depending on the circumstances, these may include ChatGPT, Claude and Gemini.
AI tools may be used for activities such as research, drafting, analysis, administration, document development or other professional work.
We do not use this statement as a blanket authorisation to submit personal data or confidential information to AI services. Any processing of personal data through third-party technology is subject to applicable data-protection requirements, data minimisation, appropriate safeguards and, where we are acting as a processor for a client, the client's documented instructions and the applicable Data Processing Agreement.
Where a third-party AI or technology provider is used in circumstances requiring additional contractual or transfer safeguards, we will assess and implement those safeguards as appropriate.
11. When We Act as a Processor for Clients
In some professional engagements, a client may provide us with personal data so that we can carry out work on the client's behalf, for example as part of compliance, governance, documentation, operational or advisory work.
Where the client determines the purposes and means of that processing and we process the data on the client's documented instructions, Polaris Partners Ltd may act as a data processor.
In such circumstances, the processing will be governed by the applicable contract and Data Processing Agreement. We will only process client personal data to the extent necessary for the agreed services and in accordance with the client's documented instructions.
We may store copies of client personal data where this is necessary to perform the agreed work. We will not use client personal data for our own unrelated purposes unless we have a separate lawful basis to do so.
12. Who We Share Personal Data With
We do not sell or rent personal data.
Depending on the circumstances, personal data may be accessed by or shared with:
- Technology and software providers used to operate the business, including Google Workspace, Calendly and HubSpot
- AI and technology providers where appropriate for business or service-delivery purposes
- Our authorised virtual assistant, who is subject to appropriate confidentiality and data-protection obligations
- Other specialist consultants or professional service providers engaged by us or, where applicable, at a client's request, subject to the relevant scope of work and contractual arrangements
- Our accountant and professional advisers where necessary for business administration, accounting, legal or regulatory purposes
- Government bodies, regulators, courts or law-enforcement authorities where disclosure is required or permitted by law
Where another organisation processes personal data on our behalf, we will use appropriate contractual and data-protection arrangements as required by applicable law.
13. International Transfers
Some of the technology and service providers we use may process personal data outside the United Kingdom or may use infrastructure located in multiple countries.
Where personal data is subject to a restricted transfer under applicable UK data-protection law, we will ensure that an appropriate lawful transfer mechanism and suitable safeguards are in place.
These safeguards may include an adequacy regulation or decision, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, or another lawful mechanism where applicable.
We will review international-transfer arrangements when material changes are made to our technology providers or processing activities.
14. Data Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure.
Measures may include access controls, account security, appropriate confidentiality obligations, contractual controls with relevant suppliers and use of reputable business technology providers.
No method of transmission or storage is completely secure. We will maintain procedures for identifying, assessing and responding to personal-data breaches and will make any notifications required by applicable law.
15. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to manage enquiries, prospective and existing client relationships, contractual obligations, legal requirements, accounting requirements and legitimate business needs.
The retention period depends on the nature of the information and the purpose for which it is held.
Website enquiries and prospect information will generally be retained only for as long as reasonably necessary to manage the enquiry or potential relationship and for appropriate legal or business purposes.
Client information processed on behalf of a client will be retained and deleted in accordance with the applicable contract, Data Processing Agreement, client instructions and relevant legal requirements.
Business and financial records will be retained for the periods required by applicable accounting, tax and legal obligations. Where information is no longer required, it will be securely deleted or otherwise disposed of where reasonably practicable.
16. Automated Decision-Making and Profiling
We do not currently make decisions about individuals using solely automated decision-making that produce legal or similarly significant effects.
We do not currently use behavioural profiling or automated website visitor profiling for advertising purposes.
17. Your Data Protection Rights
Depending on the circumstances and subject to applicable legal conditions and exemptions, you may have rights including:
- The right to be informed about how your personal data is used
- The right of access to your personal data
- The right to rectification of inaccurate or incomplete personal data
- The right to erasure
- The right to restriction of processing
- The right to object to processing based on legitimate interests
- The right to object to direct marketing
- The right to data portability where the relevant legal conditions apply
- Rights relating to certain automated decision-making and profiling
You can exercise your rights by contacting info@rivkaabecasis.com.
We may need to verify your identity before responding to a request. We will respond within the applicable statutory timeframe and in accordance with the requirements of applicable data-protection law.
18. Direct Marketing
We do not currently operate a marketing newsletter or send marketing emails through the website.
If we introduce email marketing, downloadable resources, newsletters or similar activities, we will provide appropriate privacy information at the point of collection and use the appropriate lawful basis and consent mechanism where required.
Where electronic direct marketing is subject to consent requirements under applicable privacy and electronic communications law, we will obtain the required consent and provide an appropriate means of withdrawing it.
19. Complaints
If you have a concern about how Polaris Partners Ltd has handled your personal data, please contact us first at:
info@rivkaabecasis.com
We will provide an appropriate means for you to raise a data-protection complaint and will handle complaints in accordance with applicable legal requirements.
Under the current UK data-protection framework, we will facilitate complaints and respond within the applicable timeframe. If you are dissatisfied with our response, or if you prefer to complain directly to the supervisory authority, you may contact the Information Commissioner's Office (ICO).
Information Commissioner’s Office
Website: ico.org.uk
Telephone: 0303 123 1113
The ICO's current contact details and complaint process are available on its website.
20. Children
RivkaAbecasis.com is a business-to-business website intended for adults and professional users. Our services are not directed towards children, and we do not knowingly collect personal data from anyone under the age of 18 through the website.
If you believe that a child has provided personal data to us, please contact us at info@rivkaabecasis.com.
21. Changes to This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes to our business, technology, processing activities or applicable law.
The current version will be published on this website and will show its effective date and last review date.
Where a change is material and applicable law requires us to provide additional information or notify affected individuals, we will take appropriate steps to do so.
22. Governing Law
This Privacy Notice is governed by the laws of England and Wales.
Polaris Partners Ltd | RivkaAbecasis.com | ICO Registration ZC051061