1. How We Use Your Personal Data

We are committed to protecting your personal data.

The only data we collect from you is as submitted by you on an opt-in form.

We will use your non-sensitive personal data to:

•      register you as a new client

•      manage payment

•      collect and recover monies owed to us

•      manage our relationship with you

•      send you details of our goods and services

Our legal grounds for processing your data in relation to points (i) to (iv) above are for performance of a contract with you, and in relation to (iii) and (v) above, necessary for our legitimate interests to develop our products/services and grow our business and to recover monies owed.

We will not share your details with third parties for marketing purposes except with your express consent.

In certain circumstances you can ask us to delete your data. See section 5 ‘Your Rights’ below for more information.

We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

2. Disclosure of Your Personal Data

We may have to share your personal data with:

•      service providers who provide IT and system administration support

•      professional advisors including lawyers, bankers, auditors and insurers

•      HMRC and other regulatory authorities

•      third parties to whom we sell, transfer or merge parts of our business or our assets

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.

3. International Transfers

Some of our third party providers are businesses outside of the UK/EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, codes of conduct or certification are in place which give your personal data the same protection it has within the UK/EEA. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.

4. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

In certain circumstances you can ask us to delete your data. See section 5 ‘Your Rights’ below for more information.

We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

5. Data Retention

We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements. For example, we are required to keep certain information about you for 6 years after you cease to be a client for tax purposes.

6. Your Rights

You have certain rights in relation to the personal data we process about you. Full details of these rights are available at:

ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Subject Access Requests

You may request details of the personal data we hold about you and how it is processed. To make a Subject Access Request, please email [email protected], marked for the attention of the Data Compliance Officer.

We will not charge a fee for responding unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee or decline to respond. In most cases we will reply within one month. If your request is complex or you have made multiple requests, we will notify you of any delay and will respond within three months at the latest.

How to Complain

If you are unhappy with how we have handled your personal data, you have the right to raise a complaint with us directly. We ask that complaints are made to us in the first instance so that we have the opportunity to resolve the matter.

You can make a complaint:

•      By email: [email protected] (please mark your email “Data Privacy Complaint”)

•      Online: Complaints form

We will acknowledge your complaint within 30 days and respond without undue delay. Full details of how we handle complaints are set out in our

Data Privacy Complaints Policy.

If you remain dissatisfied after we have responded, you have the right to complain to the Information Commissioner’s Office (ICO). Details of how to do this are available at:

ico.org.uk/make-a-complaint/

7. Keeping Your Data Up to Date

We have a duty to keep your personal data up to date and accurate so from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date.

If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by emailing [email protected].

8. Complaints

If you have a concern about how we have collected or used your personal data, please contact us in the first instance so that we have the opportunity to resolve it for you. Details of how to make a complaint are set out in the ‘How to Complain’ section above.

If you remain dissatisfied after we have responded, you have the right to complain to the Information Commissioner’s Office (ICO) at:

www.ico.org.uk