1: Important information and who we are
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
This version was last updated on 8 February 2022.
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.
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 a wide variety of personal data about you which will depend on the nature of our business relationship or interaction with you. We have grouped together the different types of personal data which we may collect as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender and copies of your identification documents.
- Contact Data includes residential address, registered or business address of your company, billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, 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 this website.
- Usage Data includes information about how you use our website and services and may include your feedback.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Client Data may include specific details of the services we provide you or your company or your job details.
We may need to 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). In some circumstances we may need to share such data with third parties, such as a court or tribunal in relation to the matter we act on.
If you fail to provide personal data
We need to collect certain personal data by law, in order to conduct our client due diligence during our onboarding process, or under the terms of a contract we have with you. If you fail to provide that data when requested, we may not be able to provide services to you. In this case, we may have to cancel 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 and information you provide to us
We use different methods to collect data from and about you including through direct interactions when you enquire about our services through our website or otherwise, give us feedback or contact us, or from third parties or publicly available sources. Third parties supplying us data may include our clients or other parties involved in a transaction or matter we act on, recruitment agencies, suppliers or other third parties we interact with in the course of our business.
If you provide us with personal data of other people, such as your officers and employees, your partners or family members, you confirm that you have appropriate authority to disclose such data. You further confirm that any information and data you provide to us is complete, accurate and up to date.
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 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. We will consider a number of factors to determine whether or not we can rely on legitimate interest as the basis for processing your data. This may include the nature of the data, the purpose for which we intend to process it and the information you may have provided to us.
- Where we need to comply with a legal obligation.
- Where we have obtained your consent, for example, for marketing purposes. Generally, we do not rely on consent as a legal basis for processing your personal data, but will we will obtain your consent if required by law in certain circumstances. You can ask us to stop sending you marketing messages at any time by contacting us or by clicking on the relevant link in the next marketing communication we sent to you.
We will never sell personal data to third parties for marketing purposes.
Purposes for which we will use your personal data
We may use your personal data for the following purposes:
- To register you as a new client. This may include verification of your identity, establishing the source of funding in a transaction, carrying out of money laundering checks and other appropriate due diligence which we may need to carry out in order to comply with our regulatory requirements.
- Ongoing fraud prevention, anti-money laundering, anti-bribery and the prevention or detection of crime.
- To perform our contract with you.
- To maintain our client accounts, including for the purposes of managing payments and collection and recovery of money owed to us.
- To provide you with information about our services, events, news or legal opinions which may be of interest to you. You may receive marketing communications from us if you have requested information from us or have a contract with us and you have not opted out of receiving that marketing.
- To improve our services and any content we share on our website and social channels such as by asking you to leave a review or take a survey.
5: Disclosures of your personal data
Depending on the type of services we provide to you, we may need to share your personal data with certain third parties for the purposes set out above, which may include but are not limited to:
- Other parties involved in the matter we are acting on and their professional or legal advisors;
- A court, legal Counsel or other experts, including where we are acting for you in a dispute or litigation.
- Other professional advisors or service providers whose services are required in a matter or to complete a transaction.
- Our regulators and external auditors, including SRA and the UK Information Commissioner; tax authorities and other government and law enforcement agencies; our banks, insurers and insurance brokers.
- financial organisations, and debt collection, credit reference and tracing agencies.
- Suppliers and service providers who provide us with certain services. This may include IT service providers, case management software providers, data room providers and marketing service providers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6: International transfers
We do not transfer your personal data outside the UK in the normal course of our business. If we need to transfer your personal data out of the UK, for example, for the purposes of storage, we will ensure a similar degree of protection is afforded to it.
7: Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know that data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8: Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in our Archiving, Retention and Destruction Procedure which you can request from us by contacting us.
9: Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.