Privacy Policy
Lightning Leads Limited Privacy & Data Protection Policy
BACKGROUND:
Lightning Leads Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits any of our websites: www.ppi-tax-claim.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” | means an account required to access and/or use certain areas and features of Our Site; |
“Cookie” | means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and |
“Cookie Law” | means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
Information About us
Our Site is owned and operated by Lightning Leads Ltd, a Limited company registered in England under company number 13885849.
Registered & trading address: Lightning Leads Limited, 10 Pilgrim Suite Ketteringham Hall, Ketteringham, Wymondham, England, NR18 9RS
Data Protection Officer: Gary Etherington
Email address: gary@lightningleads.co.uk
Postal Address: Lightning Leads Limited, 10 Pilgrim Suite Ketteringham Hall, Ketteringham, Wymondham, England, NR18 9RS
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on Our use of Cookies and similar technologies):
Name;
Date of birth;
Gender;
Address;
Email address;
Telephone number;
Business name;
Job title;
Profession;
Payment information;
Information about your preferences and interests;
IP address;
Web browser type and version;
Operating system;
A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, or because it is in Our legitimate business interests to use it. Your personal data may be used for the following purposes:
Providing and managing your access to Our Site;
Personalising and tailoring your experience on Our Site;
Supplying Our products or services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring Our products or services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing us)
Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on Our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for no longer than 60 days.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
The security of your personal data is essential to us , and to protect your data, we take a number of important measures, including:
Storing data on a secured server in a protected facility in England. All data is encrypted while in our possession.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails OR at the point of providing your details
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict Our use of Cookies. For more information, see Part 14.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.
How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us . we use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for tracking analysis to improve our services to you. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
the following third-party Cookies may be placed on your computer or device:
Name of Cookie | Provider | Purpose |
Xs Sb Presence Pl Fr Wd Datr c_user act | .facebook.com | We use the Facebook Like button to integrate our website with our page on Facebook.com. In order to do this Facebook implements Cookies that detect the number of “likes” and whether you are logged into Facebook or not. See Facebook’s cookie policy here. https://www.facebook.com/policies/cookies/ |
NID | .google.com | Advertising cookie by google |
CONSENT | .google.com | These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. 1 year |
UIDR | .scorecardresearch.com | This cookie contains a timestamp corresponding with the last time the UID cookie was set (or refreshed). Further information at https://www.scorecardresearch.com/Preferences.aspx |
UID | .scorecardresearch.com | This cookie contains an anonymous unique id that is generated on the Akamai servers that serve the scorecardresearch.com domains. It is also being used to store state values. The expiration on this cookie will be refreshed by 2 years if a web browser sends a request to scorecardresearch.com and the expiry is less than one year from when the request is sent. Further information at https://www.scorecardresearch.com/Preferences.aspx |
_dc_gtm_UA-10210606-1 | .unbounce.com | This cookie is associated with sites using Google Tag Manager to load other scripts and code into a page. Where it is used it may be regarded as Strictly Necessary as without it, other scripts may not function correctly. The end of the name is a unique number which is also an identifier for an associated Google Analytics account. |
NID | .google.com | Most Google users will have a preferences cookie called ‘NID’ in their browsers. A browser sends this cookie with requests to Google’s sites. The NID cookie contains a unique ID Google uses to remember your preferences and other information, such as your preferred language (e.g. English), how many search results you wish to have shown per page (e.g. 10 or 20), and whether or not you wish to have Google’s SafeSearch filter turned on. |
Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products OR services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie | First / Third Party | Provider | Purpose |
__cfduid | Third | .cloudflare.com | Used by the content network, Cloudflare, to identify trusted web traffic. |
GAPS | Third | accounts.google.com | Unclassified |
_gat | Third | Google Universal Analytics | Performance |
dpr | Third | .facebook.com | Unclassified |
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Data Protection Officer: Gary Etherington
Email address: gary@lightningleads.co.uk
Postal Address: Lightning Leads Limited, 10 Pilgrim Suite Ketteringham Hall, Ketteringham, Wymondham, England, NR18 9RS
Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
ABOUT US
We, Phillipson Hardwick Advisory Ltd, are committed to safeguarding the privacy of our prospective Clients (Prospects) and our Clients; this policy sets out how we will treat your personal information. We are a Data Controller, which means that we determine the purposes and the means of processing your personal information. We are registered directly with the Information Commissioner’s Office (ICO) and our registration number is ZB276600.
THE DATA SUBJECT (YOU)
For the purpose of data processing we will refer to you as either a Prospect, or a Client depending on your relationship with Phillipson Hardwick Advisory Ltd. For ease, we have split this policy into three sections:
– Prospect: this section is relevant to any potential Clients who have not entered into an Agreement with Phillipson Hardwick Advisory Ltd by signing our Claim Documents.
– Client: this section is relevant once you have entered into an Agreement with Phillipson Hardwick Advisory Ltd by signing our Claim Documents. This includes where you provide your signature electronically.
– Everyone: this section is relevant to all individuals who engage with us, including both Prospects and Clients.
Throughout the policy, we refer to your personal information as your data.
The Claim Documents you sign will depend on the specific service you engage us for and may include a Letter of Authority, Agreement to Proceed, Claim Form, other type of document or a combination thereof.
PROSPECTS
WHY WE REQUIRE YOUR DATA
When you provide your data to us, you consent for us to use your personal information to;
– Contact you about offering our services via the contact methods you have provided, which could include telephone, text message (SMS), messaging platforms such as WhatsApp, email and/or post; and
– Administer our website, including ensuring that we can enable your use of the services on our website (including enquiries and complaints about our website) and improve your browsing experience by personalising the website.
Further information about how we will use your data can be found in the “Everyone” section of this Privacy Policy.
THE DATA WE REQUIRE
To process your enquiry, we require that you provide your full name, date of birth, telephone number, email address and postal address. Depending on the service you are enquiring about, we may also require additional information to help us substantiate your claim(s), such as a National Insurance number. Upon receipt of your data we will attempt to contact you using the contact methods you have provided.
If you do not wish to provide the personal details we require, unfortunately, we will be unable to offer some or all of our services to you.
DATA RETENTION
We will keep your contact details following an enquiry for a maximum period of three years. During this period, we will contact you using the contact details you have provided to offer you our services as per your initial enquiry. Contact will be made using the contact methods you have provided which could include;
– Telephone, text message (SMS), messaging platforms such as WhatsApp, email; and
– Post
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers that are subject to strict security requirements.
WITHDRAWING YOUR CONSENT
You can withdraw your consent for us to contact you by telephone, text message (SMS), messaging platforms such as WhatsApp, email and/or post at any time.
You can withdraw consent verbally via telephone or in writing via email or post using the contact details at the end of this policy. Additionally, every electronic communication we send to you will contain an option to opt out.
CLIENTS
WHY WE REQUIRE YOUR DATA
During the provision of our services, you agree for us to process your personal information through signing our Claim Documents to allow us to;
– Submit information requests and/or Data Subject Access Requests to relevant third parties to obtain information about the financial product(s) you held/hold to establish if you are eligible to make a claim(s);
– Submit claims to HMRC with your instruction;
– Provide you with updates via telephone, text message (SMS), messaging platforms such as WhatsApp, email and post where such contact details have been provided; and
– Send statements and invoices to you and collect payments from you.
Further information about how we will use your data can be found under the “Everyone” section of this Privacy Policy.
DATA RETENTION
Once you have entered into a contract with us, we will keep your personal data for up to seven years following the conclusion of our contract with you.
The retention of your data enables us to provide our services to you and fulfil our legal obligations including our accounting requirements.
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers that are subject to strict security requirements.
UPDATING YOUR CONTACT PREFERENCES
You can opt-out of contact by telephone, text message (SMS), messaging platforms such as WhatsApp and/or email at any time. Whilst you have an active Agreement with us, you are unable to withdraw consent for postal communications, as we require this method of contact to fulfil our contractual and regulatory obligations.
You can update your contact preferences verbally via telephone or in writing via email or post using the contact details at the end of this policy.
EVERYONE
WHAT INFORMATION DO WE COLLECT?
We collect, store and use the following kinds of information;
– Website use – we will record information about your computer and about your visits to and use of our website, including your IP address, geographical location, browser type, referral source, length of visit and page views;
– Personal information – for example, your name, date of birth, address details and contact information;
– Special or sensitive information – data protection law defines some personal information as ‘sensitive’ for example information about your physical health. It may sometimes be necessary to collect this information to help us provide you with a better service however, we will only collect and process this type of information with your consent;
– Financial information – to investigate any potential Tax Refund claim(s) relating to tax deductions made from compensation payments you received from financial organisations, which could include the type of product (i.e.: a loan or credit card), the start and end date of the product, transactional information or account statements;
– Employment and Tax information – to investigate any potential Tax Refund claim(s) we may require information about your current employment, employment history and information about your tax status.
– Information to help us to better understand you and provide you with information about other services which may be suitable and relevant – for example, information about how you interact with electronic communications we send, such as email, text message (SMS) and messaging platforms such as WhatsApp; and
– Information about other people – if you provide personal information about someone else, for example when a Marriage Allowance claim is made, you must do so with the permission of the other person. The personal information about the other person will be used in the ways as described in this policy.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
– When you make an enquiry to us by telephone, by email, on our website, via social media, through a third party or by any other means;
– Where you instruct another third party to refer a potential claim(s) to us;
– When you provide information directly to us once you have entered into an Agreement with us by telephone, by email, on our website or by any other means;
– From a third party(ies) with your instruction, for example where you have signed our Claim Documents instructing us to make an information request or Data Access Request to a third party(ies) for the purposes of substantiating your claim(s)
– Where a third party, such as a financial organisation, HMRC or the Court provides information in response to a claim(s);
– From identity checking services, and credit reference agencies:
> we may be required by law to verify your identity and address(es) and to do so, we may undertake an electronic check. This process involves searches with credit reference agencies, fraud prevention agencies and the electoral register. The agencies will record the details of the search, but the electronic check will have no effect on your credit rating;
> where we require information about your financial product(s) to progress your claim(s) we may obtain this from an information service or credit reference agency. The information we will request will be limited to specific information about the financial products you hold/held,
such as the date(s) you opened and closed an account. As part of our request we will provide the information service or credit reference agency with your name, date of birth and contact information. The information service or credit reference agency will use this information to assist them with identity verification and prevention of fraud/money laundering.
– When you add reviews to a review platform or interact with us using social media
– When we may need to obtain up to date information about you to meet our contractual or legal obligations for example, we may use a tracing agent to find up to date contact information for you if we require your Instruction(s) to progress your claim(s) or are attempting to collect unpaid Fees; and
– Any other instance where you have given permission for your information to be provided to us.
HOW WE USE YOUR DATA?
TO PROVIDE OUR SERVICES TO YOU
– Contacting you to see how we can help if you have expressed an interest in our services, but have not signed our Claim Documents;
– Passing your personal information to financial institutions and HMRC to progress your claim(s);
– Helping you identify additional claims through undertaking “soft” searches through credit and information services;
– Responding to any enquiries that you make via email, post, or social media; and
– Storing your personal information and using it to populate fields on our websites to make it easier for you to utilise our services in the future;
What is our legal basis for processing?
– Performance of a contract;
– Consent; or
– Legitimate Interests
TO MARKET TO YOU
– Contacting you about products and services which we think may be of interest to you, for example, by email, text message (SMS), messaging platforms such as WhatsApp, post, or social media; and
– Inviting you to take part in and manage consumer surveys, reviews, and other market research activities.
Should you no longer wish to receive information about similar products and services, you can withdraw your consent for or object to receiving marketing communications from us and we will stop processing your data for marketing purposes. You can object verbally via telephone or in writing via email or post using the contact details at the end of this policy.
What is our legal basis for processing?
Consent; or
– Legitimate Interests
TO PERSONALISE YOUR JOURNEY WITH US
– Using your personal information to form a view on what services you may be interested in and tailor our marketing communications to you;
This is called profiling. We believe we have a legitimate interest to do this and that it does not harm your rights over your information. However, if you do not want us to use your personal information in this way, you have a right to object to this and can let us know using the contact details at the end of this policy.
What is our legal basis for processing?
– Legitimate interests
OTHER USES
– Internal Analysis: we may use your personal data to assess our performance as a business and for statistical analysis, as part of our legitimate interest to develop our business and our products; and
– Sale, or re-structuring: we may share your data with potential buyers of some or all of our business during a sale, or re-structuring and may rely on legitimate interests to transfer ownership of your files with us to a third party.
What is our legal basis for processing?
– Legitimate interests
LEGAL REQUIREMENTS
We may be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling. We will always inform you if this is the case.
What is our legal basis for processing?
– Legal Obligation
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
To facilitate your claim(s) and provide our services to you, we need to communicate your personal data to other individuals or organisations. Your personal data will always be processed in strict confidence and we will take all reasonable steps to ensure that any third party has adequate security measures in place.
– Progressing your claim(s): to progress your claim(s) we may be required to provide your data to named financial institutions and HMRC. Additionally, our work for you may require us to disclose information to other third parties to assist us in the investigation and progress of your claim(s) such as credit reference agencies;
– Communicating with you: we may use third party firms which provide omnichannel communication software to help us manage and send some of our email and text message (SMS) communications and/or communications on messaging platforms such as WhatsApp. We may also use an outsourced print house based in the United Kingdom to print and post letters that we send to you;
– Systems and IT: we use third party firms which support the running of our business through providing essential data storage, software and other IT services;
– Administrative support: we may outsource some elements of your claim(s) such as the processing of documentation relevant to your claim(s) and the conduct and receipt of telephone calls to specialist supervised companies based outside the United Kingdom;
– Credit and Information Services: We may share information with and use information from information services and credit reference agencies based in the United Kingdom to:
> ensure the information we hold about you is correct and up to date and to verify your identity and address in line with our obligations under the Money Laundering Regulations 2017; and to perform a “soft” credit check with the credit reference agency, where this is relevant to the service we are providing to you. For example, a “soft” credit check could be used to help us identify additional financial products you hold and may be eligible to make a claim(s) in respect of. “Soft” checks are visible to you on your credit report but do not show up to other organisations in the same way as a “hard” check and have no impact on your credit rating. We will always notify you prior to performing a “soft” check on your credit report
– Collecting our Fee(s): where you have a Fee(s) that is due to us under our Agreement but remains unpaid despite efforts on our part to recover the funds due, we may pass your personal data to third parties that support with debt management, including potential purchasers of any outstanding debt;
– Meeting our obligations: we use United Kingdom based professional legal, consultancy and accountancy services to help us fulfil our regulatory and legal obligations. In certain circumstances we may be required to provide your data to the HMRC, or other relevant body, for example the credit reference agencies, fraud prevention agencies, the Information Commissioner’s Office or a law enforcement body; and
– Other third parties: we may share your data with other third parties where we believe we have a legitimate interest to do so, such as tracing agents, review platforms, market researchers, or potential buyers of some or all of our business during a sale, or re-structuring.
If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.
Third Party Companies
In addition to the third party individuals and organisations that we use to provide our service to you, your information is also shared with:
– Rock Dove Consultants Ltd for the purpose of marketing additional services that may be of interest to you. They will contact you by telephone, post, email, and SMS. They will be the data controller.
– Phillipson Hardwick Solicitors Ltd for the purpose of providing you with legal services. They will contact you by telephone, post, email, and SMS. They will be the data controller.
LEGITIMATE INTERESTS
We may use your personal data for purposes outside of our contractual services where we believe that it is in our legitimate interest to do so. When we rely on our legitimate interest, we make sure we consider and balance any potential impact on you and your rights before we process your personal data.
Our legitimate interests are:
– to service our clients’ needs and deliver services
– to promote and market our products and services
– to understand prospects and clients including their patterns, behaviours as well as their likes and dislikes; and
– to test and develop new products and services as well as improve existing ones.
One example of this is where we rely on legitimate interests to process your personal data for marketing purposes, which is outlined in more detail later in this policy. Other examples include:
– Reviews and research: we may contact you to ask you to provide a review about the services which you have received or where we are carrying out market research which may help us design future products and services or to help improve our current services;
– Internal Analysis: we may use your personal data to assess our performance as a business and for statistical analysis, as part of our legitimate interest to develop our business and our products. We may also share this information with third parties who provide us with services and where we have a contractual obligation to do so; or
– Sale or re-structuring: we may share your data with potential buyers of some or all of our business during a sale or re-structuring and may rely on legitimate interests to transfer ownership of your file(s) with us including any ongoing claim(s) to a third party.
AUTOMATED DECISION MAKING AND PROFILING
As highlighted earlier in our Privacy Policy, we use profiling to personalise your experience with us and to allow us to better meet your needs.
Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
We only want to contact you about services that will benefit you. To support this may rely on automated decision making as part of our marketing strategy and some of the communications we send to you may be prompted by automated decision making.
You have the right to object to us profiling you for marketing purposes, or using automated decision making. You can object using the contact details at the end of this policy. Where we receive an objection from you, we will stop processing your personal information in this way within one month and confirm this to you.
YOUR DATA RIGHTS
You remain in control of your personal data and have rights over your data, we summarise some of these rights below.
You can make a request to exercise your rights using reasonable means, including by telephone, post or email. If you make the request by email, we will provide any response or information in a commonly used electronic format unless you instruct us otherwise. Where you make a request to exercise one of your rights, we will action this within one month. However, should the request be complex we can extend this by a further two months. We will inform you of this in this event.
– Accessing Your Personal Data
You have the right to request from us a copy of the personal data that we may hold about you. This is often called a ‘Data Subject Access Request’. We will provide this free of charge. However, if you make a repeat request, we may charge an administrative fee of £10. Before providing this information to you or to another person or company where you have requested this personal data to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we are only providing it where you have given your agreement.
– Correcting Your Personal Data
If the personal information we hold about you is incorrect, or incomplete you have the right to request that we correct this.
– Stopping, or Limiting the Processing Of Your Personal Data
You may request that we stop processing your data, for a specific purpose or any purpose if you believe we are no longer entitled to process it. There may be occasions where we are unable to stop processing your personal data and we will discuss this with you when responding to your request.
– Deleting Your Personal Data
If you believe that we no longer have any reason to process or hold your data, you may request that we delete this. There may be occasions where we are unable to delete your personal data due to contractual, legal or regulatory obligations. We will, however, discuss this with you when responding to your request.
– Transferring Your Personal Data
You can request your data in a commonly used electronic format, and for us to transfer this to another entity or person, where we are processing your data with your consent or in accordance with a contract. This will only apply to information which is processed by automated means (i.e. by a computer).
LEGAL REQUIREMENTS
We may be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling.
In these circumstances, we may be required to keep your data by law. We will always inform you if this is the case.
INTERNATIONAL DATA TRANSFERS
We will only share your personal information outside the United Kingdom (UK) where we have your consent, to comply with a legal duty, or where we work with a third-party service provider to enable us to provide you with our services, and they are based in or process information outside of the UK.
If we do share your information outside of the UK, we will make sure that it is protected in the same way as if it was being used within the UK.
This includes through ensuring that the transfer is covered by an appropriate safeguard or that the European Commission has made an ‘adequacy decision’ in respect of the country’s data protection measures. Although we are no longer part of the European Union (EU) the UK Government has recognised European Commission adequacy decisions made before the end of the transition period, meaning we are able to continue to transfer data to the European Economic Area (EEA) and other countries with a European Commission adequacy decision in confidence, knowing that the appropriate safeguards are in place to ensure personal data is kept safe. More information on this can be found on the European Commission Justice website or the Information Commissioner’s Office website.
In addition, some of the third-party service providers we use may be based outside of the UK or EEA and/or may provide services which mean your data is transferred outside of the EEA.
In any case, we will ensure that there are appropriate security measures in place such as technical security, including encryption and restricted access to your data. We have strict contracts in place to make sure your data is kept safe. If you have any questions, please contact us.
COOKIES
WHAT ARE COOKIES?
We use cookies, as do most website providers, to help maintain website functionality and to manage your preferences. A cookie is a small text file that a website saves on your web browser or mobile browser when you visit a website. It enables the website to remember your actions and preferences (such as login, language selection, font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.
Cookies are a widely used form of technology and most, if not all, websites will set cookies.
Cookies may be used for various purposes, including:
– User preferences, including language
– Authentication: to identify the user once logged in, for the duration of a session
– Analytics: to provide information about website use and user profile
– Targeting adverts
HOW DO WE USE COOKIES?
We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to keep track of you whilst you navigate the website. We will use the persistent cookies to enable our website to recognise you when you visit.
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We also use cookies to remember your device so we can deliver more relevant advertising to you. This means that the cookie remembers you have visited our site and will show you advertising which is relevant to you.
We use a mix of cookies. Some of these are set by our website, to manage your preferences.
We also use third party cookies. This includes Google Analytics, who gather all of your information on an anonymised basis. This allows us to make sure our website is the best it can be. Most third party cookies are on an anonymised basis, which means these organisations are not collecting any information that can be used to identify you.
We also integrate with social media providers, to help you to connect your account to our website and also to display advertising content which is relevant to you. These cookies use your personal data to deliver advertising which is relevant to your interests.
This is an overview of our cookie use which you can review to decide how best to manage your online privacy
– Functional Cookies – these are always enabled as they are required for basic website maintenance. We cannot stop these from being set on your browser, but you can manage your preferences through your browser itself
– Performance Cookies – These cookies allow us to improve the site’s functionality by analysing usage of our website on an anonymised basis. In some cases these cookies improve the speed with which we can process your request or allow us to remember site preferences you have selected. Deselecting these cookies may result in poorly- tailored recommendations and slow site performance
– Social Media and Advertising Cookies – Social media cookies offer the possibility to connect you to your social networks and share content from our website through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our websites. This means the cookie will allow you to show you adverts relating to your interests. De-selecting these cookies may result in seeing advertisements that are not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.
You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
You can easily accept or reject the cookies on this site by using the options available on our cookie banner.
THIRD PARTY WEBSITES
Our website may contain links to other websites. We are not responsible for the privacy policies or practices of third-party websites.
POLICY AMENDMENTS
We may update this privacy Policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.
CONTACT US
If you have any questions about this policy or our treatment of your personal data, please contact us:
– By email at contact@phillipsonhardwickadvisory.co.uk
– By post to Phillipson Hardwick Advisory Ltd, Centenary House, Centenary Way, Manchester, M50 1RF
– By telephoning us on 0161 518 5511
Where provided electronically, a paper copy of this policy can be made available upon request.
COMPLAINTS
If you are not happy with how we process your personal information, you should contact us using the contact details provided above, to make a complaint.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your personal information, for example, if we were to refuse to comply with a data rights request. We would however, prefer that you direct any complaints us in the first instance to we may attempt to resolve your concerns. You can find details of how to make a complaint to the ICO on their website, at https://ico.org.uk/make-acomplaint/
ICO’s address:
Information Commissioner’s Office Wycliffe House,
Water Lane,
Wilmslow,
Cheshire, SK9 5AF
Helpline Number:
0303 123 111