Last updated: April 2021
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Our full details are:
Full name of legal entity: White & Black Limited
Email address: email@example.com
Postal address: Home Park, Grove Road, Bladon, Oxfordshire, OX20 1FX
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 contact us in the first instance.
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 different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name and last name.
- Contact Data includes email address, postcode and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, 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..
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you or provide you with the legal services you have requested.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions.You may give us your Contact Data when you:
- Sign up for our E-Bulletins, News & Events (marketing);
- Make an enquiry.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client or deal with your enquiry||(a) Identity
|Necessary to conclude and perform a contract with you|
(c) Marketing and Communication
|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
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|To use data analytics to improve our website, services, marketing, client relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing (for example providing you with an opportunity to unsubscribe in any of our marketing emails). Whilst we do not share your personal data with third parties for the purpose of carrying out marketing on our behalf, we may use third party marketing platforms (for example MailChimp or Getresponse.com) to enable us to send you marketing communications. Where these providers are based outside the EEA we will ensure appropriate safeguards are in place to protect your data, as described below.
You can ask us to stop sending you marketing messages at any time by contacting us or using the link within the email. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our service.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Third Parties – these include:
- Service providers acting as processors who provide IT and system administration services, AI document analysis and storage software services, cloud-based storage and practice management services, web-hosting services, background checking or screening providers, CRM and integrated marketing platform services, event organisation services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers; auditors and insurers providing consultancy, banking, legal, insurance and accounting services.
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. We will put contracts or equivalent legal acts in place to ensure that third parties only process your personal data for specific purposes and in accordance with our strict instructions.
6. International transfers
In providing our services we most commonly process your data within the UK or the EEA. However, some of our external third-party service providers and professional advisors, for example marketing platform service providers or foreign counsel, may be based outside the United Kingdom and the European Economic Area (EEA). Whenever your personal data is transferred outside of the UK or the EEA, the transfer will be carried out in accordance with applicable data protection laws. We will take steps to ensure that an adequate degree of protection is afforded to your personal data by implementing at least one of the following safeguards:
- ensuring an adequacy decision regarding the recipient country has been approved by the European commission or the UK government, granting your personal data an equivalent standard of protection to that which it would receive in the United Kingdom or the EEA; or,
- where an adequacy decision has not been granted, we will ensure additional appropriate safeguards, such as Standard Contractual Clauses 2010/87/EU or 2004/915/EC (approved by the European Commission and the UK Government), are in place with data recipients to secure your personal data to the equivalent standards of protection it receives in the United Kingdom or the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We are committed to ensuring that your information is secure. In order to prevent your data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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. 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
How long will you use my personal data for?
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
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 – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
- Request correction of your personal data – 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 can also 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.
- 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 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 transfer of your personal data – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: 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.)
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 may 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 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.