MONDAIR SOLICITORS
PRIVACY POLICY
Introduction
Mondair Solicitors respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
This privacy notice aims to give you information on the types of data we collect and process about you, what we do with your personal data and why we use your personal data.
Mondair Solicitors is the controller and responsible for your personal data (collectively referred to as “Mondair Solicitors”, “we” or “our” in this privacy notice).
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). We would, however, appreciate the chance to deal with your concerns before your approach the ICO so please contact us in the first instance.
2. Your Personal Data
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:-
· Identity Data including first name, maiden name, last name, driving licence number, passport number, national insurance number or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes address, email address, telephone number and job title.
· Financial Data includes bank account details
· 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 our website.
· Profile Data includes your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use your website and services
· Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In certain circumstances we may collect Special Categories of Personal Data about you (this can include details about your race or ethnicity, religious or philosophical beliefs, sex live, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
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.
Third Party Links
Our website 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. How We Use Your Personal Data
We will only use your personal data when the law allow us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you
· 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 we need to comply with a legal or regulatory obligation
Where you have positively opted into receiving marketing communications from us, we will rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all 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 data
To register your interest as a new client
(a) Identity
(b) Contact
Performance of a contract with you
To register you as a new client
(a) Identity
(b) Contact
Performance of a contract with you
To deliver our service to you including managing payments
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:-
(a) Notifying you about charges to our terms in privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of 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 clients use our services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of contract with you
(b) Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business)
To administer and protect our business and this website (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 to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Technical
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, clients relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (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 goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)
Lawful Basis Glossary
· 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
· Performance of a 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 we are subject to.
Marketing
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 of you. This is now we decide which 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 used our services and, in each case, you have not opted out of receiving that marketing.
Opting Out
You can ask us to stop sending you marketing messages at any time by unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time at reception@mondair.co.uk or boota@mondair.co.uk
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 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.
4. Disclosures of Your Personal Data
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example where we are complying with legal obligations, a court order or a governmental authority.
In providing services to our clients and in complying with legal obligations, we may share your personal data with the following third parties:
· Suppliers and services providers, including IT services providers, system administrators, courier services.
· Search providers including financial organisations, credit reference, fraud prevention, identity verification and tracing agencies
· Professional advisers, including lawyers, bankers, insurers, experts and medical practitioners
· HM Revenue and Customs, government agencies, regulators or other authorities
We may have to share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
5. International Transfers
We do not require your personal data outside the European Economic Area (EEA) unless your specific matter requires that we do or unless it is necessary due to your geographic location and you have given your prior consent.
If is necessary for us to transfer your personal data outside of the EEA to the US, we use providers in the US if they are part of the Privacy Shield between the EU and US.
6. Data Security
We have put in place appropriate security measure 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, contactors 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.
7. Data Retention
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.
In some circumstances you can ask us to delete your data see below for further information. However, by law we have to keep basis information out about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection in relation to your personal data:
· Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we 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 us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 we are 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 we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we 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 us to suspend the processing of personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are 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, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
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. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
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 personal who has no right to receive it. We may also contact you to ask you for further information in relation to you request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take a little 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.