We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.
2. Whose personal data do we collect?
By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, correspondence address and your IP address if you access our website.
We may collect, use, store and transfer different kinds of personal data about you:
- Contact Data includes data such as your email address, telephone number and correspondence address
- Identity Data includes data such as first name, last name, username or similar identifier, date of birth, passport number
- Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, 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 our website and any communications we may send to you.
- Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Marketing Data includes your preferences in receiving marketing from us.
We do not knowingly collect personal data of children. Please do not provide personal data to us unless you are at least 18 years old.
Personal data you provide to us
From time to time you may provide to us personal data. This may be because:
- You provide information and documents to us so that we can verify your identity
- You access and interact with our website, including by
- creating an account with us,
- posting content on our website,
- You or your employer provides services to us;
- We provide services to you or your employer;
- You apply to work with us as an employee or a consultant;
- You provide feedback or reviews to us;
- You respond to a survey or questionnaire;
- You otherwise contact us including with queries, comments or complaints.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
Please note that we shall share your Contact Data and Identity Data with our Know Your Customer service provider, Northrow, to confirm your identity.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Personal data we automatically collect about you
When you use our website, we may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
Personal data we receive from others
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.
We may also receive personal data about you from our third party service providers, including our payment service providers, and our analytic service providers.
3. Legal basis for processing your personal data
- consent (where you choose to provide it);
- performance of our contract with you;
- compliance with legal requirements; and
- legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
We may from time to time need to use Contact Data and/or Identity Data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party's rights, property or safety.
We may also use any of your personal data for our legitimate interests including:
- to improve our website and our services;
- in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- to deal with any questions or comments you raise;
- for audit purposes; and
4. Who do we share your data with?
For our legitimate interests, we may share your personal data with our service providers, sub-contractors, consultants and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, group companies, accountants, auditors and lawyers.
Please note that we shall share your Contact Data and Identity Data with our Know Your Customerservice provider, Northrow, to confirm your identity. We send your information securely to Northrow, and Northrow, may contact you with further questions or requests about your identity. Once verified, your information will be securely sent back to us.
We shall provide our service providers, sub-contractors, consultants and agents including Northrow only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
If we need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party's rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.
5. Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.
Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.
You may consent to receive marketing email messages from us about our website and our services and business generally. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. If you still have an account with us, we shall continue to email you in relation to your account only.
8. Your rights
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here
- Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
- Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
- Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.
- Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.
- Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data
- Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.
9. Retention of personal data
This means that we shall retain your personal data for as long as you have an account with us or otherwise access or use our website. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents and in order to deal with any dispute you might raise.
Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.