What Does This Policy Cover?
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) the “GDPR” and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.
What Personal Data Do You Collect and How?
Subject to the following, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.
Our Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of Our Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.
How Do You Use My Personal Data?
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times.
As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of Our Site.
We will not share any of your personal data with any third parties for any purposes other than storage on an email and/or web hosting server.
How and Where Do You Store My Data?
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, the GDPR, and/or to equivalent standards by law.
Personal data security is essential to us, and to protect personal data, we take the following measures:
Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your personal data) including notifying you and/or the Information Commissioner’s Office where we legally required to do so.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses.
We will respond to your subject access request within 7 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: +44 (0)20 7193 5844
Postal Address: London Strand, 7 Bell Yard, WC2A 2JR
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Definitions and Interpretation
means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the EU Regulation 2016/679 General Data Protection Regulation (“GDPR”); and
means Clifford Nash, a limited company registered in England under company number 12406168 whose registered address is London Strand, 7 Bell Yard, WC2A 2JR.
We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site.
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve Our Site and your experience of it.
Functionality Cookies enable us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
It is important for us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site.
Third party Cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to us (these Cookies will work in the same way as analytics Cookies described above).
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service used by Our Site uses analytics Cookies to gather the required information.
Consent and Control
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
The links below provide instructions on how to control Cookies in all mainstream browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge
Safari (iOS): https://support.apple.com/en-gb/HT201265
For more information about our terms and conditions, please visit the following: https://cliffordnash.com/terms-conditions