PRIVACY POLICY
We take your privacy very seriously.
Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
Key terms
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to enquiries@net-solicitors.co.uk.
How your personal data is collected
We collect most of this information from you direct. However, we may also collect information:
from publicly accessible sources, eg Companies House or HM Land Registry;
directly from a third party, eg:
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sanctions screening providers;
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client due diligence providers;
from a third party with your consent, eg:
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your bank or building society, another financial institution or advisor;
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consultants and other professionals we may engage in relation to your matter;
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your doctors, medical and occupational health professionals;
via our information technology (IT) systems, eg:
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case management systems;
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door entry systems and concierge logs;
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Our computer networks and connections, communications systems, email and instant messaging systems; for example Skype and SMS
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
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to comply with our legal and regulatory obligations;
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for the performance of our contract with you or to take steps at your request before entering into a contract;
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for our legitimate interests or those of a third party; or
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where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
The above table does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
We may use your personal data to send you updates by email, or post about legal developments that might be of interest to you and/or information about our services, including any new services that we may be offering.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
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contacting us by emailing Bola Fakoya, our Data Protection Officer, email enquiries@net-solicitors.co.uk
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using the ‘unsubscribe’ link in emails
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We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
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professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
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other third parties where necessary to carry out your instructions, eg your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
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our insurers and brokers;
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external auditors;
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our banks
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external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, photocopying service, marketing agencies, document collation;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal data with any other third party.
Where your personal data is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
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to respond to any questions, complaints or claims made by you or on your behalf;
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to show that we treated you fairly;
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to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our client care letter/terms of business.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
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with your and our service providers located outside the EEA;
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if you are based outside the EEA;
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where there is an international dimension to the matter in which we are advising you.
These transfers are subject to special rules under European and UK data protection law.
Your rights
You have the following rights, which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
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complete a data subject request form— available from our Data Protection Officer
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email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
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let us have enough information to identify you [(eg your full name, address and client or matter reference number)];
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let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
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let us know what right you want to exercise and the information to which your request relates.
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics service, Google Analytics uses and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy: https://net-solicitors.co.uk/cookies-policy/. Information collected about you, once collected is anonymised and stored on an aggregate basis.
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies through our cookie control tool) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: to enable us to gain a better understanding of what our website users want so that we can improve our website and market our services accordingly.
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
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Telephone provider
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Email provider
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IT service provider
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Web developer
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Hosting provider
Our third party service providers are located in England, apart from our email service provider and hosting provider, who are located in the United States of America. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was published on 11 May 2018
We may change this privacy policy from time to time, when we do we will inform you via email and by notice on our website.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
Our contact details are shown below:
