PRIVACY AND COOKIES POLICY
© Purdy Smith Ltd 2017-2019
Purdy Smith Limited (“we”) are committed to protecting and respecting your privacy.
For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and the Data Protection Act 2018 (the “Act”), the data controller is Purdy Smith Limited of 14 Gray’s Inn Road, London, WC1X 8HN.
INFORMATION WE COLLECT ABOUT YOU
We will collect and process information you give to us. This includes information about you that you give to us by filling in forms on our site, by corresponding with us by phone, e-mail or otherwise, or by direct contact (e.g. meetings and marketing events). It includes information you provide when you subscribe to our mailing list, contact one of our lawyers, engage us to provide services or report a problem. The information you give us may include your name, job title, employer, address, e-mail address, telephone number, CV and passport details.
We may also collect limited technical information regarding each of your visits to our site including the IP address used to connect your computer to the Internet, which pages you visit and for how long and page interaction information (e.g. scrolling, clicks, and mouse-overs).
We may also collect identity and contact data about you from publicly available sources such as Companies House, business directories, press articles, your employer’s website and/or social media websites (e.g. LinkedIn, Twitter).
COOKIES AND SIMILAR TECHNOLOGIES
For the purposes of brevity, any further references to “cookies” in this policy also encompass any similar technologies that we use which involve storing information on your device or gaining access to information on your device, including web beacons and HTML5 local storage.
We use Google Analytics on our site, which relies on cookies. Google Analytics is one of the world’s most widespread and trusted analytics solution on the internet and tracks things such as how long you spend on our site and the pages that you visit. This information helps us to improve our site, for example by ensuring that users are finding what they are looking for easily and allowing us to see which particular content is proving to be popular.
Twitter feeds and/or Twitter buttons are provided on certain pages of our site. Twitter may employ a number of cookies in relation to these components.
For more information on the cookies that Google and Twitter use, please refer to their privacy policies (see https://www.google.com/policies/privacy and https://twitter.com/en/privacy respectively).
We also download a cookie to your device if you click the “OK” button on the cookies information banner that is displayed when you access our site – this is so that if you visit our site again it “remembers” that you have already seen the banner and do not need to see it again.
If you wish to block, restrict or delete cookies set by our site or any other website you can do so through your web browser's settings. Your browser’s “Help” function should tell you how to do so. However, please note that restricting cookies may impact on website functionality.
USES MADE OF THE INFORMATION
We may use your personal information in the following ways: (a) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us; (b) to contact you with information about the firm’s services, relevant legal updates, details of our events and other new which we consider may be of interest to you; (c) to carry out verification checks, for example in relation to anti money laundering and know-your-client procedures; (d) to notify you about changes to our services; (e) for the firm’s recruitment and selection purposes; and (f) for website analytics purposes.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
You also agree that we have the right to share your personal information with selected third parties including: (a) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and (b) analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets, and if Purdy Smith Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We will also disclose your personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of Purdy Smith Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for processing the personal information described above will depend on the specific information in question and the context in which it was collected.
We will typically only process your personal information if we have your consent to do so, if we need to process the personal information to perform a contract with you (e.g. a contract to provide our services) or if the processing is in our legitimate interests and these are not overridden by your interests, rights or freedoms. In certain instances, we may have a legal obligation to process your personal information or may need to process it in the context of exercising, establishing or defending legal claims.
In the event that we process your personal information to perform a contact with you or comply with a legal obligation, we will make this clear at an appropriate point. We will inform you of whether providing your personal information is mandatory or not and the potential consequences (if any) should you fail to provide it.
If you would like further information about the legal basis on which we process your personal information, including any legitimate interests we rely on, please contact us using the details set out in the “CONTACT US” section below.
The data that we collect from you may be transferred to, and stored in, countries outside the European Economic Area (“EEA”) which may have less stringent data privacy laws than those that apply in the EEA. Your data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: (a) we transfer your personal data only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or (b) we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or (c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us using the details set out in the “CONTACT US” section below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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 relation 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.
You have the following rights under data protection law: (a) the rights to access, update, correct or request deletion of your personal information; (b) the rights to object to the processing of your personal information, as us to restrict our processing of your personal information or request portability of your personal information; (c) the right to opt-out of marketing communications we send to you at any time; and (d) the right to withdraw your consent where we are processing your personal information using consent as our legal basis for doing so.
If you wish to exercise any of the rights set out above, please let us know by contacting us using the details set out in the “CONTACT US” section below.
You will not usually have to pay a fee to access your personal data or to exercise any of the other rights. However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee or alternatively refuse to comply with your request.
We may need to request specific information from you for security purposes to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. We may also contact you to ask you for further information 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 which case we will notify you and keep you updated.
LINKS TO OTHER WEBSITES
Our site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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 (see 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.