PRIVACY NOTICE

This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you, whether directly or indirectly (“personal information”). In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We take seriously the protection of your privacy and confidentiality. We understand that you are entitled to know that your personal data will not be used for any purpose unintended by you, and will not accidentally fall into the hands of a third party.

Our policy complies with UK law, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

We never sell any of your personal information and, except as set out below, we do not share, or disclose to a third party, any of your personal information.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information. We set put below the bases on which we rely.

If all of the bases on which we process your personal information are no longer relevant then we shall immediately stop processing your data.



1. Information we process because we have a contractual obligation with you

When you engage our services a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

1.1. verify your identity for security purposes
1.2. provide you with our services

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.



2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you ask us to provide you more information about our services, you provide your consent to us to process information that may be personal information.

By giving us information about yourself you are consenting to our using this information as described in point 1 above.

We may from time to time pass your information to third parties to enable to comply with our contractual obligations to you.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by notifying us in writing. However, if you do so, you may not be able to use our services further.



3. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

whether the same objective could be achieved through other means

whether processing (or not processing) might cause you harm

whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:

record-keeping for the proper and necessary administration of our business

responding to unsolicited communication from you to which we believe you would expect a response

protecting and asserting the legal rights of any party

insuring against or obtaining professional advice that is required to manage business risk

protecting your interests where we believe we have a duty to do so.



4. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Other Matters



5. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If you have a complaint about the way in which we are managing and processing your personal data you may complain to the Information Commissioner’s Office.



6. Access to your personal information

At any time:
6.1. you may review personally identifiable information that we hold about you, by requesting in writing that we supply it to you
6.2. you may ask us in writing to correct any inaccuracies or to erase personal information when it is no longer necessary for us to retain it.
After receiving the request, we will tell you when we expect to provide you with the information or take the action requested.



7. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.



8. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
8.1. to provide you with the services you have requested or may request in the future;
8.2. to comply with other law, including for the period demanded by our tax authorities;
8.3. to support a claim or defence in court.


9. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website. We advise you to print a copy for your records.


If you have any question regarding our privacy policy, please contact us.