POLICY ON MATTERS OF PRIVACY AND PERSONAL DATA
POLICY ON MATTERS OF PRIVACY AND PERSONAL DATA
Last update: 18-02-2020
Here at LegalRM, we are committed to protecting your privacy and security online. You have control over the information we store about you and what types of information (if any) you would like to receive from us.
Our website: www.legal-rm.com.
This notice is separated into the following sections for ease of reference.
If you have any questions about this notice or how we collect and use personal information about you please contact us.
We are Legal RM Limited. Our registered office is at 4 Cobden Court, Wimpole Close, Bromley, Kent, BR2 9JF, UK and our registered company number is 06025162.
If you have any questions, our contact details are:
• +44 (0) 208 289 8529, or
• email@example.com, or
We use data for different purposes and in different situations. Full details on the data we collect and why we collect it can be found below.
When you enter into a contract with us (or someone does so on your behalf) there will be personal information about you relating to that contract such as your name, contact details, contract details, delivery details, and correspondence with us about the contract.
We need certain information to carry out our contract with you and you must provide this in order to enter into a contract with us (or as required under that contract), if you do not, we may not be able to carry out our contract with you. Mandatory information fields are generally set out when you are entering into the contract, but in particular, you must provide the following information:
• Your name and contact details.
• Your delivery address.
• Your payment details.
• Information to verify your identity and other information for us to carry out anti money laundering checks.
Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and us, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
Call information. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
We will keep and use that information to carry out our contract with you (if applicable), to comply with any legal requirements for us to maintain certain records or carry out certain verifications, and/or for our legitimate interests in dealing with a complaint or enquiry and administering your (or your organisation’s) account or order.
Where your information relates to a contract, it is kept for a period of up to 6 years after your account is closed to enable us to deal with any after sales enquiries or claims and as required for tax purposes.
Payment information is collected by our payment card processing provider and is retained for a period of up to 6 years after the date of the order.
Any other information is kept for 6 years.
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about the products and services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes if you have expressed an interest in receiving marketing information from us. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so.
You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by unsubscribing our emails or by emailing us on firstname.lastname@example.org. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact you for administrative or if we have an ongoing contract or are dealing with an outstanding complaint, but we will make sure that those communications don’t include direct marketing.
If you are an existing customer or are acting as a business we use your contact details in compliance with GDPR for our legitimate interests in marketing to you and maintaining a list of potential customers.
If you are not an existing customer, and are not acting as a business, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party).
We never share your name or contact details with third parties for marketing or any other purposes unless we have your “opt-in” consent to share your details with a named third party for them to send you marketing. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list. We keep that securely held with limited access indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.
We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely. See our Cookies Policy for more details.
We, or third party advertisers, may also use this information to serve adverts on you. Where those adverts are targeted, this may involve using website information and information we (or our third party advertisers) have obtained from third parties. This won’t include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interests in marketing to you.
If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
We keep this information for up to 6 years after the end of our relationship with your organisation.
We will collect and hold information on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.
We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.
If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.
Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
We may also receive information about you from the following sources:
• Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out above.
• Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services or products we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
• Publicly available sources. We obtain information from publicly available sources such as Twitter Facebook, or LinkedIn, etc.
• Credit information. We may also collect credit information on you from third party reference agencies.
We do not collect any “special categories” of more sensitive personal information 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, as well as information about criminal convictions and offences).
Common uses of your information. We will only use your personal information when the law and you allow us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:
• we need to perform a contract we have entered into with you.
• we need to comply with a legal obligation.
• it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
• we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
As well as any sharing listed above, we may also share your information with third parties outside the EU, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law. We never sell your data to third parties.
Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Which third-party service providers process your personal information?
We also may need to share your personal information for third-party service providers (including contractors and designated agents) so that they can carry out their services.
The following activities are carried out by third-party service providers: legal advice, contract administration, order fulfilment, delivery, administration, IT services, payment processing.
When might we share your personal information with other entities in the group?
We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
How secure is your information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Our office headquarters are based in Bromley and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers. In particular, we operate in the following countries: USA and Canada.
Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfill 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
• Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
• 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 information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
• Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) 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 interest in doing so.
• Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us (see section 1).
No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.