Privacy Policies
MBM Commercial respects your privacy and is committed to protecting your personal data. These privacy notices will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
General Privacy Policies
MBM Commercial LLP is a legal firm providing legal advice and services to our clients. In order to do this, we will process personal data of (i) current or past clients of MBM Commercial (including employees of clients where they are a legal entity), (ii) those who are on MBM Commercial’s marketing database or are a contact of MBM Commercial or (iii) a supplier of goods or services to MBM Commercial.
This privacy notice is provided to anyone whose data we process and we have provided it in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice gives information on how MBM Commercial collects and processes your personal data, our legal obligations under applicable data protection law and your rights as a data subject. It also contains information about who to contact if you want to exercise any of your rights in relation to our personal data processing including who to contact if you wish to make a complaint.
CONTROLLER
MBM Commercial LLP is the data controller and responsible for your personal data (collectively referred to as the “Firm", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions about this privacy notice, the way we process personal data or want to exercise your rights under data protection law, please contact the data privacy manager using the details set out below.
CONTACT DETAILS
Andy Harris, Partner, IP Data & Contracts (“Data Privacy Manager”)
andy.harris@mbmcommercial.co.uk
MBM Commercial LLP
Edinburgh Office
Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS
T. 0131 226 8200
COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority in relation to any 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 consider contacting our Data Privacy Manager in the first instance. You can get in touch with us using any of the above contact details.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in March 2024.
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.
If you would like us to update any of your personal data including contact information, please contact our Data Privacy Manager.
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). |
The nature of the services we provide means the types of data we process can be quite varied, but we will normally collect names, contact details and associated information. We have grouped together different categories of personal data in the tables below (depending on our relationship with you). Details of how we use the different categories of personal data and our lawful basis for processing is set out in the tables in section 4 below:
(i) Categories of personal data which may be processed about clients and contacts of MBM Commercial:
Category of Data | Type of data included |
Identity Data | First name, maiden name, last name, title, date of birth, passport details, drivers licence details, previous employment/work details, current employment details, other photographic identity documents required for anti-money laundering purposes. |
Contact Data | Billing address, postal address, email address and telephone numbers |
Financial Data | Bank account details, payment card details, salary, employment benefits, details of insolvencies, bankruptcy details, details gained from searches in the Register of Inhibitions. |
Share Transfer Data | Names, address, bank account details, salary details, disclosure letter details, death certificates, deeds of probate and/or confirmation, copy of wills share-holding details, share option details where applicable. |
Disclosure Data | Employment history details, bankruptcy details, details of directorships and consultancy arrangements |
Marketing and Communications Data | Name, company name, email address, preferences in relation to receiving marketing materials from us. |
Special Categories of Personal Data | 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 |
Criminal Convictions and Offences | Details of past criminal convictions or offences |
(ii) Categories of personal data which may be processed about contacts on the MBM Commercial marketing database:
Category of Data | Type of data included |
Identity Data | First name, last name, title, company name, job position |
Contact Data | Email address, marketing preferences |
(iii) Categories of personal data which may be processed about third party suppliers
Category of Data | Type of data included |
Identity Data | First name, last name, title, company name, job position |
Contact Data | Email address, postal address, telephone number |
Financial Data | Bank account details, and payment card details. |
IF YOU FAIL TO PROVIDE PERSONAL DATA
The personal data above is required to enable us to fulfil our relationship with you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. We collect information directly from you and/or your organisation when you fill in forms or by contact us. This includes personal data you provide:
Client and contact personal data |
|
Marketing database personal data |
|
Supplier personal data |
|
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Client and contact personal data |
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Supplier personal data |
|
4. HOW WE USE YOUR PERSONAL DATA
The personal data we collect is processed to provide legal services to our clients and for our own general business purposes including (without limitation):
- providing legal advice or other services our clients need;
- operating and managing our business (including administering our clients’ accounts and tracing and collecting any debts), enhancing client care and general improvement of our services;
- fraud prevention, anti-money laundering, anti-bribery and for the prevention or detection of crime;
- disclosures to our auditors, our own legal and other professional advisors, our insurers and insurance brokers.
We also process personal data for advertising and marketing purposes, including sending you direct marketing communications (where we are permitted to do so under the data protection rules).
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA AND OUR LAWFUL BASIS.
We will only use your personal data when the law allows us to do and where we have a lawful basis for doing so.
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.
- Where we need to comply with a legal obligation.
- Where you have provided your consent.
We have set out below, in a table format, a summary of: (i) the purpose for which we use your personal data; (ii) the categories of personal data that we collect; and (iii) our lawful basis for processing your personal data. We have also identified what our legitimate interests are where appropriate.
CLIENT AND CONTACT PERSONAL DATA:
Purpose/Activity | Categories of Data | Lawful Basis |
To enter into a contract with you and open a file for you to enable us to provide legal services to you, and all related administrative procedures | (a) Identity Data (b) Contact Data (c) Financial Data |
|
To perform anti-money laundering checks and creditworthiness checks | (a) Identity Data (b) Contact Data (c) Financial Data |
|
To manage our relationship with you which will include but not be limited to:
| (a) Identity Data (b) Contact Data (c) Financial Data |
|
To provide day to day legal services which will include:
| (a) Identity Data (b) Contact Data (c) Financial Data |
|
To recover monies owed:
| (a) Identity Data (b) Contact Data (c) Financial Data |
|
Disclosure exercises | (a) Identity Data (b) Disclosure Data |
|
Share Transfers as part of a corporate transaction | (a) Identity Data (b) Contact Data (c) Financial Data (d) Share Transfer Data |
|
Litigation/Employment work | (a) Identity Data (b) Contact Data (c) Financial Data (d) Special Categories of Personal Data (depending on the specific work in question) (e) Criminal Convictions and Offences (depending on the specific work in question) |
|
Sending you marketing materials and newsletters | (a) Marketing and Communications Data |
|
MARKETING DATABASE CONTACT PERSONAL DATA
Purpose/Activity | Categories of Data | Lawful Basis |
Sending you marketing materials | (a) Identity Data (b) Contact Data | Necessary for our legitimate interest - in developing and growing our services Consent |
SUPPLIER PERSONAL DATA
Purpose/Activity | Categories of Data | Lawful Basis |
To enter into a contract with you in order for you to provide goods or services for us, and all related administrative procedures | (a) Identity Data (b) Contact Data (c) Financial Data |
|
To manage our relationship with you which will include but not be limited to:
| (a) Identity Data (b) Contact Data (c) Financial Data |
|
MARKETING
You may receive marketing communications from us if you (i) have requested marketing communications from us, (ii) have consented to marketing communications from us, or (iii) have paid for services from us or expressed an interest in our services, and we have assessed that it is in our legitimate interest to send you related marketing information that we think you would be interested in, in order to continue to run and grow our business.
In each case, we will not send any marketing communications if you have asked us to stop contacting you or opted out of receiving that marketing.
5. SHARING YOUR PERSONAL DATA
We may share personal data we hold with any member of our group, which means, where applicable, our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may also have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties set out below:
Who? | Detail |
Certain Third Parties | Third parties involved in any matter, including courts, counter parties, other advisors and experts involved in a matter. |
Service Providers | Service providers acting as processors including those who provide IT and system administration services, file storage services, debt collection agencies, financial services and marketing services. |
Professional Advisors | Professional advisors acting as processors, controllers or joint controllers including lawyers, legal counsel, mediators, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services. |
Authorities | Authorities such as HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. |
Other third parties | 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. |
- When personal data is shared with third parties service providers it is limited to that which is required for providing the service.
- We require all third party service providers 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 who are data processors 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
Some of our external third parties may, from time to time, be based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office.
- If we use certain service providers based outside the UK, we may use specific contracts approved by the Information Commissioner’s Office which give personal data the same protection it has in the UK.
- In any other case, we will obtain your explicit consent before any transfer takes place.
Please contact our Data Privacy Manager if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
The safety of your personal data is of utmost important to us. As such, we have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, as solicitors we maintain confidentiality in relation to our clients’ information (which includes personal data). Access to all client information is restricted to authorised personnel who are subject to a duty of confidentiality.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
Below we set out the key retention periods. Further details can be obtained by contacting our Data Privacy Manager.
Data type | How long will you keep my data? |
Client Files | Client files will generally be kept for as long as you are a client of the Firm and thereafter for 10 years in accordance with Law Society of Scotland rules. |
Supplier Information | Supplier information will be kept for as long as we have an active contract or agreement in place with a supplier, plus 5 years. |
Marketing Database Contact personal data | Personal data of individuals within our marketing database are usually obtained on the basis of consent. There is no fixed time limit after which consent automatically expires and consent will remain valid for as long as we believe that it is a correct indication of the person’s current wishes. If there is a significant change in circumstances, then we shall seek new consent. |
9. YOUR LEGAL RIGHTS
As a data subject, you have rights under data protection laws in relation to your personal data. We will not normally charge a fee for you to exercise these rights (unless your request is manifestly unfounded or manifestly excessive). Details of the individual rights you have are set out below
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
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.
Review by an independent authority. You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Website Privacy Policies
MBM Commercial LLP is a legal firm providing legal advice and services to our clients. In order to do this, we will process personal data of (i) current or past clients of MBM Commercial (including employees of clients where they are a legal entity), (ii) those who use our website, (iii) those who are on MBM Commercial’s marketing database or are a contact of MBM Commercial or (iv) a supplier of goods or services to MBM Commercial.
This privacy notice is provided to anyone whose data we process and we have provided it in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW YOUR PERSONAL DATA IS COLLECTED
- HOW WE USE YOUR PERSONAL DATA INCLUDING OUR LAWFUL BASES
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy policy gives information to anyone whose data MBM Commercial collects and processes, including any data you may provide through this website, when you sign up to our newsletter or use our Contact Us form.
This website is not intended for children and we do not knowingly collect data relating to children.
We also have a more detailed privacy notice for clients which is available here.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
CONTROLLER
MBM Commercial is the data controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy.)
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy.
If you have any questions about this privacy notice, the way we process personal data or want to exercise your rights under data protection law, please contact the data privacy manager using the details set out below.
Contact Details
Andy Harris, Partner, IP Data & Contracts (“Data Privacy Manager”)
andy.harris@mbmcommercial.co.uk
MBM Commercial LLP
Edinburgh Office
Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS
T. 0131 226 8200
COMPLAINTS
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 consider contacting us in the first instance.
CHANGES TO THE PRIVACY POLICY
This version was last updated in March 2024.
THIRD-PARTY LINKS
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 policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
WHAT IS PERSONAL DATA?
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). |
The nature of the services we provide means the types of data we process can be quite varied, but we will normally collect names, contact details and associated information. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, date of birth, title, company name
- Contact Data includes email address, address and telephone numbers.
- 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 Site.
- Usage Data includes information about how you use our Sites and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. We collect information directly from you and/or your organisation when you fill in forms, questionnaires, or otherwise contact us. This includes personal data you provide when you:
- contact us about our Services;
- apply to attend a seminar or event;
- apply for a job;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers, such as Google;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data and/or Usage Data. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
4. HOW WE USE YOUR PERSONAL DATA
The personal data we collect is processed to provide legal services to our clients and for our own general business purposes including (without limitation):
- providing legal advice or other services our clients need;
- operating and managing our business (including administering our clients’ accounts and tracing and collecting any debts), enhancing client care and general improvement of our services;
- fraud prevention, anti-money laundering, anti-bribery and for the prevention or detection of crime;
- disclosures to our auditors, our own legal and other professional advisors, our insurers and insurance brokers.
We also process personal data for advertising and marketing purposes, including sending you direct marketing communications (where we are permitted to do so under the data protection rules).
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA AND OUR LAWFUL BASES
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.
- Where we need to comply with a legal obligation.
- Where you provide your
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we currently use and plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity |
Categories of Data |
Lawful Basis |
To respond to any query you make via our website using our Contact Us form |
(a) Identity data (name, title, company name) (b) Contact data (Email address, phone number) Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted. If you choose you may also provide us with special category data. |
Necessary for our legitimate interest (for running our business, providing our services) |
To respond to any query you make via our website using our Seed Investment interest form |
(a) Identity data (name, title, company name) (b) Contact data (Email address, phone number) Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted |
Necessary for our legitimate interest (for running our business, providing our services) |
To respond to any query you make by email |
(a) Identity data (name, title, company name) (b) Contact data (Email address, phone number) Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted |
Necessary for our legitimate interest (for running our business, providing our services) |
To respond to a request by you to be informed about our events |
(a) Identity data (name, title, company name) (b) Contact data (Email address, phone number) Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted |
Necessary for our legitimate interest (for running our business, providing our services and for marketing purposes, to develop our services and grow our business) |
To use data analytics to improve our website, services, marketing, customer relationships and experiences |
(a) Technical data (including internet protocol (IP) address) (b) Usage data (information about how you use our website and services) |
Necessary for our legitimate interest (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (essential cookies) Consent (non-essential cookies) Please see our Cookie Policy for further information |
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy |
(a)Identity data (name, title, company name) (b)Contact data (Email address, phone number) |
Necessary to comply with a legal obligation |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a)Identity data (name, title, company name) (b)Contact data (Email address, phone number) (c)Technical data (including internet protocol (IP) address) |
Necessary for our legitimate interest (for running our business, provision of administration and IT services, network security and to prevent fraud) |
Marketing
You may receive marketing communications from us if you (i) have requested marketing communications from us, (ii) have consented to marketing communications from us, or (iii) have paid for services from us, or expressed an interest in our services, and we have assessed that it is in our legitimate interest to send you related marketing information that we think you would be interested in, in order to continue to run and grow our business.
In each case, we will not send any marketing communications if you have asked us to stop contacting you or opted out of receiving that marketing.
Objecting to or Opting Out of Marketing You can ask us to stop sending you marketing messages at any time. The unsubscribe option will be in every marketing email that you receive, or you can update your marketing preferences by contacting us at marketing@mbmcommercial.co.uk |
Cookies
This website uses cookies to help it function and to improve it. For more detailed information about the cookies we use, please see our Cookie Policy.
5. SHARING YOUR PERSONAL DATA
We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 above.
Third party |
Detail |
Service providers: |
including those who provide:
|
Authorities: |
including HMRC, the Law Society of Scotland and other and authorities who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction |
Corporate partners: |
includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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. |
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
Some of our external third parties may, from time to time, be based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office.
- If we use certain service providers based outside the UK, we may use specific contracts approved by the Information Commissioner’s Office which give personal data the same protection it has in the UK.
- In any other case, we will obtain your explicit consent before any transfer takes place.
Please contact our Data Privacy Manager if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
The safety of your personal data is of utmost important to us. As such, 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, as solicitors we maintain confidentiality in relation to our clients’ information (which includes personal data). Access to all client information is restricted to authorised personnel who are subject to a duty of confidentiality.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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.
Data you give us using our Contact Us form and Seed Investment Registration form will only be retained for 60 days before it is deleted, unless you go onto become a client in which case your personal data will be held in accordance with our internal Data Retention Policy.
9. YOUR LEGAL RIGHTS
As a data subject, you have rights under data protection laws in relation to your personal data. We will not normally charge a fee for you to exercise these rights (unless your request is manifestly unfounded or manifestly excessive). Details of the individual rights you have are set out below.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information 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.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Review by an independent authority. You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager. |
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 may 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.
Cookies Policy
- Our website uses cookies to help it function and to improve it. Cookies (and similar technologies) are small files of letters and numbers that are saved to your computer’s hard drive when you visit a website.
- Cookies are used by most websites and can do a number of things, including tracking, saving and storing information about your interactions and usage of a website.
- There are two types of cookies: (a) essential or strictly necessary cookies which are used to enable a website to function and (b) non-essential or analytics cookies which are commonly used to complie records of browsing histories and to better understand your experience while visiting a website.
- Our website uses both essential and non-essential cookies and details of the types of cookies we use are set out in the tables below.
- We are allowed to place essential cookies on your device without consent (so long as we have told you about this – which we have done through our cookie banner and this policy). For non-essential cookies, we need to get your express consent (and this only needs done once when you first use our website). This can be done by looking at the cookie settings of this website and setting your preferences. You can update these preferences at any time in the same way. If you wish to deny the use and saving of cookies from our website onto your computer’s hard drive you should change your web browser’s security settings to block all cookies from our website upon your first visit.
How do I change my cookies setting?
- Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit https://www.aboutcookies.org/ or www.allaboutcookies.org.
- Find out how to manage cookies on popular browsers:
- To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout
Which cookies do we use?
- The two tables below set out the cookies which are used on our website. The first table relates to the Google Analytics cookies and the second table refers to all other cookies.
(i) Measuring Website Usage (Google Analytics)
We use traffic log cookies to identify which pages are being used. In particular, portions of this website use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). We use Google Analytics software to collect information about how you use this website. This helps us analyse data about web page traffic and improve our website in order to tailor it to client needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
- Google Analytics stores information about:
- the pages you visit
- how long you spend on each page
- how you got to the site
- what you click on while you’re visiting the site
- Your IP address will be used by Google for the analytic purposes set out above. The information they use is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- We will not use this information for any other purpose. We don’t allow Google to use or share our analytics data.
Universal Analytics
Google Analytics
|
Google Analytics sets the following cookies in accordance with Google’s privacy policy:-
(ii) Other cookies that are used on our website, together with details of their purpose, are as follows:
Category |
Name |
Purpose |
Duration |
Joomla Sessions Cookie (essential) |
joomla_user_state |
Our website is powered by the Joomla web Content Management System (CMS). By default, Joomla CMS automatically installs a cookie into your web browser as soon as you visit this website. Below, this cookie is referred to as a "session" cookie; that means, the cookie lasts only as long as your current session when using our website. |
When you close your browser |
CallRail Call Tracking (non-essential) |
calltrk_landing |
Tracks the website or webpage landed on by the visitor. |
1 year |
calltrk_referrer |
Tracks the last website visited prior to landing on our website. |
1 year |
|
calltrk_session_##### |
Provides an identifier for the user visiting the website |
1 year |
|
Google reCAPTCHA |
These are essential site cookies, used by the google reCAPTCHA to reduce spam on our site. These cookies use an unique identifier for tracking purposes. |
When you close your browser
|
|
PREF |
|||
NID |
|||
HSID |
|||
APISID |
|||
SID |
|||
Hubspot |
__hstc |
Set by our marketing partner HubSpot, inc. The main cookie for tracking visitors. |
2 years |
hubspotutk |
Set by our marketing partner HubSpot, inc. This cookie is used for to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. |
10 years |
|
__hssc |
Set by our marketing partner HubSpot, inc. Cookie for keeping track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. |
30 minutes |
|
__hssrc |
Set by our marketing partner HubSpot, inc. Whenever HubSpot changes the session cookie, this cookie is also set. |
Session |