Appleton Company Services Limited trading as The London Law Agency ("London Law") Privacy Notice
London Law is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from), including when you purchase a product or services or sign up to our newsletter. It also tells you about your rights and how the law protects you.
1 Important information
Our website
is not intended for children and we do not knowingly collect data relating to
children.
This
Privacy Notice supplements the other notices (including our terms of use (Terms)) and is not intended to override
them.
London
Law is the controller and responsible for your personal data (we, us or our.
To assist you
further in understanding this Privacy Notice, we have set out in Part
5 of Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we
use it, the lawful basis for processing such data and further details of your
rights.
We
have appointed a data privacy manager (DPM).
If you have any questions about this Privacy Notice, including any requests to
exercise your legal rights, please contact our DPM in writing, either:
by email to: info@londonlaw.co.uk
by
post to: 1st Floor, 8 Bridle Close
Kingston Upon Thames KT1 2JW
You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first
instance.
Your duty to inform us of changes
It is important that the data we hold about you
is accurate and current, therefore please keep us informed of any changes to
your personal data.
Third-party links
Our
website may include links to third-party websites, plug-ins and applications. By
clicking on these links or enabling connections you may be allowing third
parties to collect or share your personal data. We have no control these
third-party websites, plug in or applications and are not responsible for their
privacy notices, therefore you should also read their privacy notices to
understand what personal data they collect about you and how they use it.
2 The data we collect about you
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
3 How personal data is collected
We collect personal
data in the following ways:
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direct
interactions
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you may provide
personal data when you complete online forms, request products/services, subscribe
to our services, create a user account, join our mailing list, or otherwise
or correspond with us (by post, phone or email)
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automated
technology
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we automatically
collect personal data (technical and usage) when you browse or interact with
our website, by using cookies, server logs and other similar technologies. We
may also receive technical data about you if you visit other websites which
use our cookies. For further details please see our cookie notice at the end
of this document.
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publicly
available sources
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we may collect personal data from
publicly availably sources such as Companies House and the Electoral Register
and credit reference agencies, based inside the EU.
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third
parties
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we may receive personal data from: (a) analytics providers based outside the EU(such
as Google); (b) advertising networks, such as Yell based [inside OR outside]
the EU]; and (c) search information providers [such as Yell.com based inside
OR outside the EU; (d) our suppliers such as payment providers, delivery
services, website support and maintenance providers.
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4 How we use your personal data
We
will only use your personal data when the law allows us to. Most commonly, we
will use your personal data:
- to perform the contract, we are
to enter into or have entered into with you;
- to comply with a legal obligation;
and
- where it is necessary to carry
out our legitimate interests (or those of a third party) and your
interests and fundamental rights do not
override those interests.
Part 2 of Schedule 1
sets out the lawful basis we
will rely on to process your personal data.
We
do generally only rely on consent as a legal basis for processing your personal
data to send email and SMS marketing communications and you have the right to
withdraw your consent at any time by contacting us. Please 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 information.
Marketing
We may analyse your personal
data to form a view on what products and or services we think may be of
interest to you. You will only receive marketing communications
from us, if you have requested information from us or purchased services from
us, if you consent to marketing at the time we collect your personal data and
you have not subsequently opted out or withdrawn your consent or if we have
another basis to send you the marketing communications.
We will not share
your personal data with third parties for their marketing purposes.
How to opt out
You can opt out of email marketing by clicking the unsubscribe
button within the particular marketing email.
You can also withdraw your consent to marketing at any time by
contacting our DPM.
Even
if you opt out of receiving marketing, we may still
use your personal data for other purposes provided we have a lawful basis to do
so.
Change of purpose
We
will only use your personal data for the purpose that we originally collected
it for, 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
use your personal data in this manner.
We
may process your personal data (without your knowledge or consent) where this
is required or permitted by law.
5 Disclosure
of your personal data
We
may have to share your personal data with third parties further details of
which are set out in >Part 4 of Schedule 1. 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. They can only process your personal data for specified
purposes and in accordance with our instructions.
6 International
transfers
Some of our external
third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data 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:
- we 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.
- we use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe with our services providers;
- we may transfer data to US
based service providers under the Privacy Shield which requires them to provide
similar protection to personal data shared between the Europe and the US.]
Please contact us if
you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7 Data security
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. We also limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know
and they can only process your personal data on our instructions and will be subject
to a duty of confidentiality.
We
have procedures in place 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.
8 Data retention
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.
Details
of retention periods for different aspects of your personal data are available
in our retention policy which you can request from us.
However, we are legally required to keep basic information about our customers (including contact,
identity, financial and transaction data) for six years after they cease being
customers, for tax purposes.
We
may also anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes. We can use anonymised
information indefinitely without further notice to you.
9 Your legal rights
You
have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1.
If you wish to exercise any of your rights,
please contact our DPM
You
will not have to pay a fee to exercise any of your rights. However, if your
request is clearly unfounded, repetitive or excessive, we may charge a
reasonable fee for this information or refuse to comply with your request.
We
may request specific information from you to help us confirm your identity when
you contact us and ensure. This is a security measure to ensure that personal
data is not disclosed to any person who does not have the right to receive it.
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.
Schedule 1
Part 1
Types of personal data
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contact data
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billing
address, delivery address, email address and telephone number
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financial data
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bank
account and payment card details
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identity data
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first
name, maiden name, last name, username or similar identifier, marital status,
title, date of birth and gender
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marketing and communication data
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your
preferences in receiving marketing from us and our third parties and your
communication preferences
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profile data
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your
username and password, purchase or orders made by you, preferences, feedback and
survey responses
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technical data
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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
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transaction data
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details
about payments to and from you and other details of products and services you
have purchased from us
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Part 2
Lawful basis for processing and
processing activities
The lawful basis upon which we may rely on to process your personal data
are:
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consent
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you have given your express consent for us to process your personal
data for a specific purpose
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contract
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the processing is necessary for us to perform our contractual
obligations with you under our contract, or because you have asked us to take
specific steps before entering into a contract with you
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legal obligation
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the processing is necessary for us to comply with legal or
regulatory obligation.
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legitimate interests
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the processing is necessary for our or a third partyâ??s legitimate
interest e.g. in order for us to provide the best service to you via our
website. Before we process your personal data on this basis we make sure we
consider and balance any potential impact on you, and we will not use your
personal data on this basis where such impact outweighs our interest
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Set out below are specific details of the processing activities we
undertake with your personal data and the lawful basis for doing this.
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Purpose/Activity
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Type of data
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Lawful basis for
processing
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to register you as a new customer
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identity & contact
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to
perform our contract with you
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to process and deliver your order, manage
payments, fees and charges and debt recovery
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identity, contact, financial, transaction and marketing
& communications
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(i)
to perform our contract with you;
(ii)
as necessary for our legitimate interest in recovering debts due to us.
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to manage our relationship with you, notifying
you about changes to our Terms or Privacy Notice and ask you to leave a
review or take a survey
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identity, contact, profile & marketing & communications
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(i)
to perform our contract with you
(ii)
as necessary to comply with a legal obligation
(iii)
as necessary for our legitimate interests in keeping our records updated and analysing
how customers use our products/services.
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to administer and protect our business and this
website (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
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identity, contact & technical
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(i)
as necessary for our legitimate interests in 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
(ii)
as necessary to comply with any legal obligations
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to deliver relevant website content/advertisements
to you and measure or understand the effectiveness of our advertising
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identity, contact, profile, usage, marketing
& communications & technical
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as
necessary for our legitimate interests in studying how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy
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to use data analytics to improve our website,
products/services, marketing, customer relationships and experiences
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technical & usage
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as
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
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to make suggestions and recommendations to you
about goods or services that may be of interest to you, including promotional
offers
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identity, contact, technical, usage & profile
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as
necessary for our legitimate interests to develop our products/services and
grow our business
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Part 3
Your legal rights
You have the following legal rights in relation to your personal
data:
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access your data
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you
can ask for access to and a copy of your personal data and can check we are
lawfully processing it
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correction
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you can ask us to correct any incomplete or
inaccurate personal data we hold about you
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erasure
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you
can ask us to delete or remove your personal data where:
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below);
(c) we may have processed your information unlawfully; or
(d) we are required to erase your personal data to comply with local
law.
We
may not always be able to comply with your request for specific legal reasons,
which will be notified to you at the time of your request
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object
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you can object to the processing of your personal data where:
(a) where we are relying on our legitimate interest (or those of a
third party) as the basis for processing your personal data, if you feel it
impacts on your fundamental rights and freedoms;
(b) 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 and in such circumstances,
we can continue to process your persona data for such purposes
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restrict
processing
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you
can ask us to us to suspend or restrict the processing of your personal data,
if:
(a) you want us to establish the accuracy of your personal data;
(b) our use of your personal data is unlawful, but you do not want us
to erase it;
(c) you need us to hold your personal data (where 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 personal data, but we need to
verify whether we have overriding legitimate grounds to use it
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request a
transfer
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you
can request a transfer of your personal data which is held in an automated
manner and which you provided your consent for us to process such personal
data or which we need to process to perform our contact with you, to you or a
third party. We will provide your personal data in a structured, commonly
used, machine-readable format
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withdraw
your consent
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you can withdraw your consent at any time
(where we are relying on consent to process your personal
data). This does not affect the lawfulness of any processing carried out
before you withdraw your consent
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Part 4
Third Parties
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service
providers
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acting
as processors or controllers based in the EEA but also around the world who
provide server services and IT and system administration services.
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professional
advisors
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acting
as processors or joint controllers including lawyers, bankers, auditors and
insurers based in the United Kingdom who provide consultancy, banking, legal,
insurance and accounting services
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HM Revenue
& Customs, regulators and other authorities
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acting
as processors or joint controllers based in the EEA who require reporting of
processing activities in certain circumstances
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third
parties
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third
parties 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
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Part 5
Glossary
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aggregated data
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information
such as statistical or demographic data which may be derived from personal
data but which cannot by itself identify a data subject
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controller
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a
body that determines the purposes and means of processing personal data
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data subject
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an
individual living person identified by personal data (which will generally be
you)
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personal data
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information
identifying a data subject from that data alone or with other data we may
hold but it does not include anonymised or aggregated data
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processor
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a
body that is responsible for processing personal data on behalf of a controller
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special categories of personal data
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information
about race, ethnicity political opinions, religious or philosophical beliefs,
trade union membership, health, genetic, biometric data, sex life, sexual
orientation.
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ICO
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Information
Commissionerâ??s Office, the UKâ??s supervisory authority for data protection
issues
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Part 6
Cookies
Our website and company formation application
requires you to accept cookies, not accepting them would prevent you from
taking full advantage of the website or using our company incorporation
facilities.
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Cookie name
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Cookie Description
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ASP.NET_Sessionid
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ASP.NET
issues a cookie called ASP.NET_SessionId. This cookie contains the user's
session ID and the cookie will expire at the end of the session (when you
close your browser). This cookie does not store personal data about you.
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__utma
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This
cookie is typically written to the browser upon the first visit to your site
from that web browser. If the cookie has been deleted by the browser
operator, and the browser subsequently visits your site, a new __utma cookie
is written with a different unique ID. This cookie is used to determine
unique visitors to your site and it is updated with each page view.
Additionally, this cookie is provided with a unique ID that Google Analytics
uses to ensure both the validity and accessibility of the cookie as an extra
security measure.
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__utmb
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This
cookie is used to establish and continue a user session with your site. When
a user views a page on your site the Google Analytics code attempts to update
this cookie. If it does not find the cookie, a new one is written and a new
session is established. Each time a user visits a different page on your
site, this cookie is updated to expire in 30 minutes, thus continuing a
single session for as long as user activity continues within 30-minute
intervals. This cookie expires when a user pauses on a page on your site for
longer than 30 minutes. You can modify the default length of a user session
with the _setSessionCookieTimeout() method.
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__utmc
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This
cookie is no longer used by the ga.js tracking code to determine session
status.
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__utmz
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This
cookie stores the type of referral used by the visitor to reach your site,
whether via a direct method, a referring link, a website search, or a
campaign such as an ad or an email link. It is used to calculate search
engine traffic, ad campaigns and page navigation within your own site. The
cookie is updated with each page view to your site.
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__utmv
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This
cookie is not normally present in a default configuration of the tracking
code. the __utmv cookie passes the information provided via the _setVar()
method, which you use to create a custom user segment. This string is then
passed to the Analytics servers in the GIF request URL via the utmcc
parameter. This cookie is only written if you have added the _setVar() method
for the tracking code on your website page.
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__utmx
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This
cookie is used by Website Optimizer and only set when the Website Optimizer
tracking code is installed and correctly configured for your pages. When the
optimizer script executes, this cookie stores the variation this visitor is
assigned to for each experiment, so the visitor has a consistent experience
on your site. See the Website Optimizer Help Center for more
information.
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