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We at Harper James respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice sets out the types of personal information we collect, how we collect and process that information, who we may share it with in relation to the services we provide and certain rights and options that you have in this respect.
Harper James is the controller and is responsible for your personal data. Our registered address is Floor 5, Cavendish House, 39-41 Waterloo Street, Birmingham, B2 5PP. We can be contacted on 0800 6841700 and by emailing us at: firstname.lastname@example.org. We are registered with the UK data protection regulator (Information Commissioner’s Office (ICO)). Our unique registration number is ZA05916.
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. This is known as anonymous data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Technical Data including analytics providers such as Google based outside of the EU, advertising networks and search information providers. We may receive Contact Data through online publicly available sources for example, corporate websites, corporate profile sites such as LinkedIn and government registers such as Companies House.
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:
Purposes for which we will use your personal data
We have set out below, a description of 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|
|Business development||(a) Identity(b) Contact||Necessary for our legitimate interests to improve our range of services to you and to ensure you receive the relevant service|
|To register you as a new client which will include(a) client engagement including verification checks||(a) Identity(b) Contact||(a) Performance of a contract with you(b) Legal obligation|
|To manage our relationship with you which will include(a) carrying out our services to you(b) collect our fees or costs||(a) Identity(b) Contact(c) Profile(d) Marketing and Communications(f) Financial data||(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services|
|To administer and protect our business including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||(a) Identity(b) Contact(c) Technical||(a) 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)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||(a) Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about our services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile||Necessary for our legitimate interests to develop our products/services and grow our business|
|Suppliers, experts and other service providers||(a) Identity(b) Contact(c) Transaction data(f) Financial data||(a) Performance of a contract with you(b) Necessary to comply with a legal obligation and statutory/regulatory obligations (e.g. money laundering).|
|Recruitment: Potential candidates||(a) Identity(b) Contact(c) Special categories of data (where you disclose to us).||(a) Performance of a contract with you (steps taken in the first instance where your CV is first submitted to us).|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased our services and in that instance, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Harper James for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
When visitors come to harperjames.co.uk, third parties (such as AdRoll) may place cookies on their browsers for targeted advertising purposes. Instructions to opt out of targeted advertising are required to be listed. The instructions on how to opt out of receiving targeted (personalized) advertising can be found here - AdRoll's opt-out article
Cookies and other technologies
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. 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.
We may have to share your personal data with the parties set out below for the purposes set above;
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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In the course of providing our legal services to you, there may be occasions where your service requires us to transfer personal data out of the EEA. Similarly, where we use cloud service providers (customer relationship management systems), ultimately the storage of that data can be based outside the EEA.
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;
If you would like to find out more about our safeguards please contact us at email@example.com.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
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 for tax and legal purposes. In some circumstances you can ask us to delete your data: see “Your data protection rights” below for further information.
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 notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
What we need from you
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. 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.
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.
If you wish to exercise any of the rights set out above, please contact us.
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. The ICO website is https://ico.org.uk.
Changes to the privacy notice and your duty to inform us of changes
Where we make changes to our privacy notice we shall let you know. 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.
This version was last updated in May 2018.
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