Introduction
I respect your privacy and I am committed to protecting your personal data. This privacy policy will inform you as to how I look after your personal data when you visit this website (Site) and tell you about your privacy rights and how the law protects you.
Data controller
The data controller and one of the date processors in relation to the information collected on this website or otherwise is Peter Garry of First Floor, 48 Chancery Lane, London WC2A 1JF, United Kingdom (“I”, and “me”, and “my” should be interpreted accordingly).
I can be contacted using this contact information.
Your rights
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). I would, however, appreciate the chance to deal with any concerns before you approach the ICO so please contact me in the first instance using the contact form on this Site.
From 25 May 2018, under the EU General Data Protection Regulations (GDPR), all data controllers are required to provide the information contained in this privacy policy concerning the collection, retention and processing/use of personal data belonging to others.
Although this privacy policy sets out your rights under the GDPR, I may not yet be able to respond to some of your requests pursuant to the new privacy rights until after 25 May 2018, as I am still working towards getting ready for some of these changes.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
Your rights under the GDPR are set out in the Glossary below.
Data collection, retention and processing/use
I collect, retain and process/use your basic personal data in order to:
- provide you with marketing communications and other information, including bulletins, articles and newsletters, and information about the services I and my colleagues at Keystone Law Limited (Keystone) can offer you and updates about our activities,
- monitor and consider which of my services and the services of my colleagues at Keystone you might be interested in, and
- if you contact me with a view to seeking to instruct me to act for you as your solicitor via Keystone Law, for the purposes of exploring that possibility and, if appropriate, taking steps to put that retainer into effect and advising and representing you via Keystone Law.
For email bulletins I use GetResponse, an email marketing service. GetResponse’s Privacy Policy describes what personal data it collects and how it uses it. You may contact GetResponse directly to request access to information that GetResponse may hold about you.
If you make an enquiry about me acting for you or advising you as your solicitor via Keystone, then I may well share your data with Keystone and communicate with you via Keystone’s email system.
I will not collect any personal data from you that I do not need for the purposes referred to above, save as specified below.
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).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:
- Identity Data includes name, company or organisation, job title, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from me.
- 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 Site.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use my Site, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from me and GetResponse and your communication preferences.
I 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, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy policy.
I 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 I collect any information about criminal convictions and offences.
How is your personal data collected?
I use a variety of methods to collect data from and about you including through:
- Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
- express interst in or access my or Keystone’s products or services;
- create an account on this Site;
- subscribe to my bulletin service or other publications;
- request marketing to be sent to you;
- leave a comment
- participate in a survey or quiz; or
- give me feedback.
- Automated technologies or interactions. As you interact with this Site, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. I may also receive Technical Data about you if you visit other websites employing my cookies. Please see my Cookie Policy for further details.
- Third parties or publicly available sources. I may receive personal data about you from various third parties and public sources, for example:
- Technical Data from the following parties: (a) analytics providers such as Google based outside the EU; (b) advertising networks based inside or outside the EU; and (c) search information providers based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
- Identity and Contact Data from data brokers or aggregators inside or outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside and outside the EU.
- Social media
How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
- Where I need to perform a contract or retainer we (or you and Keystone Law) are about to enter into or have entered into.
- 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 I need to comply with a legal or regulatory obligation.
Generally I 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. You have the right to withdraw consent to marketing at any time by contacting me via the contact form on this Site or by clicking on an unsubscribe link in one of my emails.
Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client or customer of mine or Keystone’s or to explore that possibility | (a) Identity (b) Contact |
Performance of a contract or retainer with you |
| To process and deliver your order, retainer or instructions including: (a) Manage payments, fees and charges (b) Collect and recover money owed to me or Keystone |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract or retainer with you as above (b) Necessary for our legitimate interests (to recover debts due to me or to Keystone) |
| To manage the relationship with you which will include: (a) Notifying you about changes to my terms or privacy policy (b) Asking you to leave a review or comment or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract or retainer with you (b) Necessary to comply with a legal obligation (c) Necessary for my legitimate interests (to keep my records updated and to study how visitors, customers or clients use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract or retainer with you (b) Necessary for my legitimate interests (to study how visitors, customers or clients use my/Keystone’s products/services, to develop them and grow my or Keystone’s business) |
| To administer and protect my business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise or sale of my bsuiness or assets) (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 I serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for my legitimate interests (to study how visitors, customers or clients use my products/services, to develop them, to grow my business and to inform my marketing strategy) |
| To use data analytics to improve this Site, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for my legitimate interests (to define types of customers for my products and services, to keep this Site updated and relevant, to develop my business and to inform my marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for my legitimate interests (to develop my products/services and grow my business) |
Marketing
I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Opting out
You can ask me or GetResponse to stop sending you marketing messages at any time by logging into their 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 me at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a product/service purchase, retainer/contract warranty registration, or other transaction.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see my Cookie Policy.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.
If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
I may have to share your personal data with the parties set out below for the purposes set out in the table above:
- Internal Third Parties as set out in the Glossary below.
- External Third Parties as set out in the Glossary below.
- Any specific third parties listed in the table above.
- Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my 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 my instructions.
I will not disclose your personal data to any person where to do so would constitute a breach of my professional obligations as a Solicitor of the Senior Courts of England and Wales.
International transfers
I share your personal data with GetResponse (an internet marketing service). This may involve transferring your data outside the European Economic Area (EEA) or outside your own jurisdiction if not within the EEA.
Some of my external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented :
- I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where I use providers based in the US, I 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 the Europe and the US.
Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.
Data security
I 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, I 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 my instructions and they are subject to a duty of confidentiality.
I 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 I am legally required to do so.
Data retention
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are set out in the table above.
By law I (and/or Keystone if you become or seek to become a client of Keystone) may have to keep basic information about my/our clients or customers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being clients or customers for tax, regulatory or other purposes.
In some circumstances you can ask me to delete your data.
In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Your rights under the GDPR are summarised in the Glossary below.
If you wish to exercise any of these rights, please contact me.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
What I may need from you
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. I make sure we consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or I am otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
THIRD PARTIES
Internal Third Parties
- members of staff;
- consultants; and
- service providers.</>
External Third Parties
- Keystone Law Limited.
- GetResponse who send out marketing and other informational materials on my behalf in accordance with this Privacy Policy. GetResponse may in turn use sub-processors.
- Service providers based around the world who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based around the world who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other national, federal, state or local authorities based in the United Kingdom and/or around the world.
- Law enforcement agencies
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that I am lawfully processing it.
- Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I 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 me to delete or remove personal data where there is no good reason for me to continue to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where I am 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 I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
- Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.
Use of Cookies
Please see my Cookie Policy.
Third party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and I am not responsible for their privacy statements or their use of your data. When you leave this Site, I encourage you to read the privacy policy of every website you visit.
Modifications
I reserve the right to modify or amend this privacy policy at any time. The effective date from time to time will be displayed at the end of this privacy policy. To keep you informed, I will notify users of material changes to this privacy policy either by email and/or by prominently announcing the updated privacy policy on this Site for a period of not less than two weeks.
Effective date
The effective date of this Privacy Policy is 24 May 2018.
