Cade & Co LLP (“we” “us” “our”) is committed to protecting and respecting your privacy. As a data controller we will process your personal data in accordance with the Data Protection Act 1998 as amended or replaced by the General Data Protection Regulation 2016 and any national laws which relate to the processing of personal data (“data protection legislation”).
Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it. This policy applies to information we collect about: Visitors to our website, Customers, Introducers and Suppliers
VISITORS TO OUR WEBSITE
We may collect and process personal data about you in the following circumstances:
- whenever you provide information to us, for example making an enquiry, completing the online contact form, making a complaint or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
- when you visit our Site, we may retain details such as traffic data, location data, weblogs and other communication data, and the resources that you access (see section on Cookies below)
We may also collect data in the following ways:
- Website Links: Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites.
- IP Address: We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to analyse aggregate information. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
We may use your personal data for our legitimate interests to:
- provide you with information, or services that you requested from us;
- respond to an enquiry submitted via our online contact forms;
- ensure that content from our Site are presented in the most effective manner for you and for your device;
- process and deal with any complaints or enquiries made by you; and
- contact you for marketing purposes where you have signed up for these (see section 7 for further details)
To provide services to customers we will collect details such as:
- address history,
- email, contact number(s),
- date of birth,
- employment and tax details,
- financial information,
- health and lifestyle information.
- details of credit checks undertaken where you have supplied these to us.
We will share customer personal information with our employees to manage our relationship with you and we will retain customer personal data for as long as you are a customer of Cade and Co LLP. After you stop being a customer, we may keep your data for up to 10 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes.
We will use your personal data provided to comply with our contractual obligations arising from the agreements we enter with our Customers and share the data with financial institutions who can assist in the provision of financial services to customers including product providers, lenders, banks, insurers, fund managers, and platform providers.
We will use customer personal data for our legitimate interests including:
- sharing personal data with Tenet Group Limited and its associated companies as they provide compliance services to us. Further details regarding how Tenet will use customer personal data can be found on it’s website at tenetgroup.co.uk or by contacting Tenet on 01132390011
- with your consent, marketing our other products and services by mail and email; and
- with your consent, obtaining your sensitive personal data from third parties including your health, ethnic origin, or criminal prosecutions from third parties such as employers and credit reference agencies, fraud prevention agencies and other similar organisations.
We will collect details such as contact names, address, email address and telephone number to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of ten years from the date of our last contact with you.
We may use customer personal data to provide you with details about our services, products, and business updates which we think may be of interest. We will never sell your data, will keep your records secure and will never share them with third parties for marketing purposes.
You have the right to opt-out of receiving the information detailed in section 7.1 at any time. To opt-out of receiving such information you can:
- tick the relevant box situated in the form on which we collect your information;
- clicking the unsubscribe button contained in any such communication received; or
- email us at email@example.com or call 01604 832932 providing us with your name and contact details.
Where you have subscribed to receive marketing correspondence from us we will keep your personal data for ten years from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:
- for performance of a contract we enter into with you;
- where necessary for compliance with a legal obligation we are subject to; and
- for our legitimate interests (as described within this policy).
We will also process your personal data including personal sensitive data where we have obtained your explicit consent.
DISCLOSURE OF YOUR DATA to third parties
In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:
- staff members to facilitate the provision of services to you;
- IT software providers that host our website and store data on our behalf; and
- to a prospective buyer of some or all of our business or assets, in which case personal data including Your Data will also be one of the transferred assets.
We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will not sell or distribute your personal data to other organisations without your approval.
CROSS-BORDER DATA TRANSFERS
We do not transfer personal data outside the EEA without ensuring that safeguards are in place (for example using Microsoft or other cloud storage solutions). For data sent to the USA, transfer it only to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
Where this changes in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation.
Information you provide to us is shared internally on encrypted cloud servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 information transmitted to our site; any transmission is at your own risk.
ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF YOUR DATA
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided. This may, of course, prevent us from being able to provide a service to you.
You can also ask us to undertake the following:
- update or amend your personal data if you feel this is inaccurate;
- remove your personal data from our database entirely;
- send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract;
- restrict the use of your personal data; and
- provide you with access to information held about you and for this to be provided in an intelligible form.
We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please send any requests relating to the above to our Privacy Officer at 1 High Street, Harpole, Northampton NN7 4DH specifying your name and the action you would like us to undertake. Note that in relation to requests to access personal data, we reserve the right to charge a reasonable fee to comply with your request.
RIGHT TO WITHDRAW CONSENT
Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at firstname.lastname@example.org or 01604 832932.
Last updated: 05/04/2018.
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