1. IMPORTANT INFORMATION AND WHO WE ARE
The Firm referred to in the Contact section of this Website is the controller (i.e. is responsible for the keeping and use of your personal information).
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 27th March 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name.
- Contact Data includes email addresses, telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Where we have a need and lawful basis to do so, this data is recorded and used strictly in line with our Data Protection Policy. Any information about criminal convictions and offences will only be collected where there is a lawful basis to do so.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with certain services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. The Website includes functions that allow you to give us your Identity and Contact Data by signing up to our newsletter or requesting a call back or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Instruct or are interested in utilising our services;
- Subscribe to our blogs or publications;
- Request marketing information about our services to be sent to you;
- Enter a competition, promotion or complete a survey; or
- Give us some feedback on our services.
- Automated technologies or interactions. As you interact with the Website we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract for services we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|TYPE OF DATA
|LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
|Necessary for our legitimate interests (the interests of our business to enable us to communicate with you and provide information concerning the aim of our business and explain the functionality of the Website which we think will be of interest to you). You provide your email address as you expect to receive such communication. Without providing such communications to you being someone interested in our business this will impact on the number of new clients we have. In each instance, the functionality has been included so that you will be unable to provide your personal details until you tick a box that you have read and agree to the Policy. All communications we do send to you are tailored to the content you are interested in and you have the option to ‘unsubscribe’ if you no longer wish to receive any communications from us.
|To manage our relationship with you which will include:
|To enable you to complete a survey
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us by signing up to the newsletter on the Website or have purchased services from us or if you provided us with your details when you completed a survey or registered for marketing and, in each case, you have opted in to receipt of that marketing.
You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
What are cookies? Cookies are small pieces of data that websites store on your browser when you visit them. They are useful because they allow us to recognise your visit and collect information about how you use our website.
You can choose which types of optional Cookies you want to accept and can manage your settings at any time.
Some of our webpages and emails contain pixel tags (also referred to as web beacons, web bugs, tracking pixels, java tags and clear gifs). These allow us to:
- collect information on how you use our websites and interact with our emails (for example, the number of users who have visited a page, opened an email or followed links)
- retarget users who have come from social media or email by personalising online services, marketing communications and ads.
The tags we use don’t collect or store any of your personal or identifiable information and are fully compliant with data protection law.
Accept or block Cookies
You can block or delete any Cookies from any website by activating the setting on your browser. However, please note if you block all Cookies you might not be able to access all or part of our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
|TYPE OF DATA
|LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
|Personal information is stored within an online marketing platform. The core platform is hosted by StablePoint in the UK.
|Performance of a contract with you Necessary for our legitimate interests (for running our business, archiving data, provision of administration and IT services, network security, to prevent fraud and data breach. All personal data is kept within the platform and we have full control of the data within the platform.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.