the course of our business. We are committed to collecting and using such data fairly and in
accordance with the requirements of the General Data Protection Regulation (GDPR).
WHAT PERSONAL INFORMATION WE GATHER
We collect information about you when you register for and use our services, while delivering our
services, evaluating our services and attend our business events.
We have collated these into groups as follows:
• Your identity includes information such as first name, last name, title, date of birth, and other
identifiers that you may have provided at some time.
• Your contact information includes information such as billing address, delivery address, email
address, telephone numbers and any other information you have given to us for the purpose of
communication or meeting.
• Your financial data includes information such as your bank account and payment card details.
• Transaction data includes details about payments or communications to and from you and
information about products and services you have purchased from us.
• Technical data includes your 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.
• Your profile includes information such as your username and password, purchases or orders made
by you, your interests, preferences, feedback, and survey responses.
• Marketing data includes your preferences in receiving marketing from us; communication
preferences; responses and actions in relation to your use of our services.
• We may also collect information when you voluntarily complete client surveys or provide feedback
to us. Information relating to usage of our website is collected using cookies.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can
identify you in any way, we treat the combined data as personal information, and it will be used in
accordance with this privacy notice.
HOW WE USE THE INFORMATION
We collect information about you to deliver our services, manage your account and to email/contact
you about related information or services that we think may be of interest to you.
We do not share your information with any other party without your express permission, or if required
to do so by any statutory, governmental, or regulatory body for legitimate purposes.
In order to deliver our services to you effectively we may send your details, with your permission, to
third parties such as those that we engage for professional compliance or other related services as
well as product providers that we use to deliver our services.
Where third parties are involved in processing your data we will have a contract in place with them to
ensure that the nature and purpose of the processing is clear, that they are subject to a duty of
confidence in processing your data and that they will only act in accordance with our written
We will not share your information for marketing purposes with other companies.
THE BASIS ON WHICH WE PROCESS INFORMATION ABOUT YOU
The law requires us to determine under which of six defined basis we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data. If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION WITH YOU
When you create an account on our websites, buy a product or service from us, or otherwise agree to our terms and conditions, 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:
• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our websites
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.
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.
INFORMATION WE PROCESS WITH YOUR CONSENT
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our websites or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
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 instructing us [[email protected]]. However, if you do so, you may not be able to use our website or our services further.
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
INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION
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.
HOW LONG WE KEEP HOLD OF YOUR INFORMATION
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
In the event our relationship comes to an end, we will keep hold of your information for up to 1 year. We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do
so. In any case, we’ll not keep your personal data for longer than 6 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to any regulatory restrictions and legitimate interests.
INFORMATION RELATING TO YOUR METHOD OF PAYMENT
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of Stripe, or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
INFORMATION ABOUT YOUR DIRECT DEBIT
When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank [NatWest] for processing according to our instructions.
We keep this information only for the duration of the direct debit arrangement.
We are registered under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation.
Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures.
Once approved, they are required to give indemnity guarantees through their banks.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE
COOKIES AND OUR WEBSITE
You can set your browser not to accept cookies and the following websites will provide more information as to how to do this: www.allaboutcookies.org or https://ico.org.uk/for-thepublic/online/cookies/
We would like to send you information about products and services of ours and other companies which may be of interest to you. If you have agreed to receive marketing information, you may opt out at any time.
You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the contact details noted below.
ACCESS TO YOUR INFORMATION AND CORRECTION
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact us using the contact details noted below. We may charge a small admin fee for this service.
We want to make sure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
ENCRYPTION OF DATA SENT BETWEEN US
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
HOW YOU CAN COMPLAIN
If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO).
This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
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:
• to provide you with the services you have requested.
• to comply with other law, including for the period demanded by our tax authorities.
• to support a claim or defence in court.
COMPLIANCE WITH THE LAW
However, ultimately it is your choice as to whether you wish to use our website.
HOW TO CONTACT US