PRIVACY POLICY
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how replaceyourplates.co.uk collects and processes your personal data, through us providing you with legal services, or through your use of our website (replaceyourplates.co.uk), including any data you may provide to us when you sign up to any newsletter, marketing emails, a seminar or event.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
replaceyourplates.co.uk is the controller and responsible, alongside you, for your personal data (collectively referred to as ” replaceyourplates.co.uk”, “we”, “us” or “our” in this privacy notice).
We have voluntarily appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the data privacy manager
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 you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
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.
The data we collect about you
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 might include the following:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery 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 services you have purchased from us.
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 website.
Profile Data includes your username and password, your interests, services you have purchased from us, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect certain Special Categories of sensitive personal data about you including details about:
Your race or ethnicity,
Your religious or philosophical beliefs,
Your sex life or sexual orientation,
Your political opinions,
Any trade union membership,
Information about your health and genetic and biometric data,
The commission or alleged commission by you of any offence, including any proceedings in respect of any such offence.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We may collect data from and about you in different ways, including through:
Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, through our website or otherwise.
Third parties or publicly available sources. We may receive personal data about you from third parties, including professional advisors, counterparties, opponents, courts, witnesses, and from publicly available sources.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we anticipate that we use your personal data in the following circumstances:
Performance of a contract. To perform our contract with you, or to take any steps requested by you prior to the formation of a contract with you. If there is a contract in place with you, this is likely to be the primary legal basis for processing your personal data.
Legitimate Interest. Where it is necessary for our legitimate interest in our business in conducting and managing our business to enable us to give you the best service 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 to by law). We have legitimate interests in complying with our legal and professional obligations, in the case of processing your data for marketing purposes, marketing our services to you, and in developing new systems and providing staff training and information sharing internally, to measure and improve the performance of our website in order to provide you with the best possible visitor experience in circumstances where your personal data is appropriately protected from misuse by technical measures, policies and procedures.
In the case of Business to Business subscribers to or requestors of our digital content or registrations for our events, and our clients, in establishing and maintaining a two-way enduring and mutually beneficial relationship with you and in the case of processing your data for marketing purposes, in marketing our services including providing information about our services which are or may be of interest to you.
Compliance with a legal or regulatory obligation. Where we need to comply with a legal or regulatory obligation to our clients or third parties, for example in respect of our professional obligations to you and third parties, to our regulators, to the courts and tribunals, and to identify our clients and report any suspected money laundering activities to the National Crime Agency.
Generally, we 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, text message, post or social media. Once given, you have the right to withdraw consent to marketing at any time by contacting us.
Sensitive Personal Information
It may be necessary for us to process some sensitive information about (classified in the Special Categories of Personal Data) referred to above in paragraph 2, in order to comply with legal or regulatory obligations, or if we need to do so in order to seek confidential legal advice or establish or defend legal claims. Otherwise, we will only process your sensitive personal data with your explicit consent. If you voluntarily send us your sensitive personal data, we shall treat that as your explicit consent for us to hold that data, which otherwise shall only be processed in accordance with this policy. Where such data is processed by us on the basis of your explicit consent, you may withdraw your consent at any time: this will not affect the lawfulness of any processing based on your consent before you withdrew it.
Marketing
The primary legal basis for processing your personal data in respect of marketing is to provide you with information about our services which we consider might be of interest to you. From time to time we may invite you to events that we run jointly with other organisations. If you register for such an event then we may share your contact details with that organisation.
We may also send you questionnaires or surveys about issues that we think might be relevant to you, or for research purposes. We or our appointed agents, with whom we have appropriate data sharing agreements, in place may also occasionally telephone you to discuss these matters.
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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO COOKIE POLICY].
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Current and former directors, employees, workers, consultants, and contractors in the course of their duties or otherwise in the ordinary course of our business.
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, HM Land Registry, Companies House, regulators (including Solicitors Regulatory Authority) and other public authorities, agencies and public registries, acting as processors or joint controllers.
Service providers, acting as processors or joint controllers, who provide identity, anti-money laundering compliance checks, and credit checks.
Witnesses, counterparties, opponents, courts and tribunals.
Couriers and process server acting as processors who provide delivery services in accordance with the terms of our contract with them and to the extent required by us to perform our contract with you.
Our insurers and insurance brokers.
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.
International transfers
We may transfer your personal data outside the UK which may mean that your data is not protected in the same way as it is in the UK. We may also transfer your personal data outside of the European Economic Area, in which case we will take steps to ensure that the level of protection afforded to the personal data is similar to that afforded to in the UK.
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. In addition, we 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 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.
Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers for not less than seven years after they cease being clients for tax and regulatory purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we 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.
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 we are lawfully processing it.
Request correction of the personal data that 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 your 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.
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 person who has no right to receive it. We may also contact you to ask you for further information in relation to your 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 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.