This privacy notice provides you with details of how we collect and process your personal data either through both your use of our site www.tudor-rose.com as well as any information you may give us to allow and help us provide our services and to carry out business activities.
We need to collect and use certain types of personal information about the people we deal with, such as current, past and prospective clients, suppliers, affiliates, employees, professional contacts and others with whom we communicate.
In addition, we may occasionally be required, by law or via our professional body to collect, use and share certain types of personal information to comply with the requirements of government departments, agencies and regulators.
Under the Data Protection Legislation, all organisations which handle personal information must comply with a number of important principles regarding the privacy and disclosure of this information.
We believe that the lawful and correct treatment of personal information is critical to our successful operation. We recognise that to maintain our professional reputation and integrity, we must be fully compliant with this legislation.
By providing us with your data, you warrant to us that you are over 13 years of age.
Data Protection Legislation
In the United Kingdom and the European Economic Area (EEA), “Data Protection Legislation” means all applicable data protection and privacy legislation or regulations including The Privacy and Electronic Communications (EC Directive) Regulations 2003 (also known as PECR) and any guidance or codes of practice issued by the European Data Protection Board or the Information Commissioner, together with:
- prior to 25 May 2018, the UK Data Protection Act 1998; and
- from 25 May 2018 onwards Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”), as amended by the UK Data Protection Bill.
Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:
- be processed fairly, lawfully and transparently;
- be collected and processed only for specified, explicit and legitimate purposes;
- be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
- be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
- not be kept for longer than is necessary for the purposes for which it is processed; and
- be processed securely.
We are accountable for these principles and must be able to show that we are compliant.
Additionally, we will ensure that:
- there is someone with specific responsibility for data protection in the organisation
- we take appropriate technical and organisational security measures to safeguard personal information; and
- we ensure that personal information is not transferred abroad without suitable safeguards.
- we regularly review and audit how we handle personal information.
- the ways we handle personal information are clearly described.
- everyone handling personal information understands that they are responsible for following good practice.
- everyone handling personal information is appropriately trained and properly supervised.
- we regularly assess the performance of people who handle personal information.
- anybody wanting to make enquiries about handling personal information knows what to do; and
- queries about handling personal information are dealt with properly and courteously.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by either emailing us at TRIMarketing@tudor-rose.com, or by liaising directly with your known contacts at Tudor Rose or by writing to us at Kingfisher Business Park, London Road, Stroud, Gloucestershire GL5 2BY, or calling us on +44 (0) 1453 732880.
The types of personal data we collect and use
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender, National Insurance numbers.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account details and other financial details.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
- We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnic origin, religious or philosophical beliefs, your trade union membership, genetic and biometric data, sex life, sexual orientation, and information about your health. We do not collect any information about criminal convictions and offences.
Using your personal data: the legal basis and purpose
We will process your personal data:
- As necessary to perform our contract with you and to update our records
- As necessary for our own legitimate interests e.g. for good governance and managing our business operations and to send you marketing communications (or those of a third party) and your interests and fundamental rights do not override those interests. You have the right to challenge our legitimate interests and request we stop this processing.
- As necessary to comply with a legal obligation e.g. when you exercise your rights under data protection law and make requests; for compliance with legal and regulatory disclosures, for establishment and defence of legal rights; to verify your identity and anti-money laundering checks.
- Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at TRIMarketing@tudor-rose.com.
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 you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at TRIMarketing@tudor-rose.com.
- If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
Subject to applicable data protection law we may share your personal data with:
- Government bodies and agencies in the UK e.g. HMRC and Companies House;
- Sub-contractors and other persons who help us provide our services;
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Service providers who provide IT and system administration services.
- Courts, to comply with legal requirements;
- In an emergency or to otherwise protect your interests;
- Anyone else where we have your consent or as required by law.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
International Transfer of Data
We are based in the UK but sometimes your data may be transferred outside the EEA. If we do transfer data outside the EEA we will make sure there are suitable safeguards in place, for example by using approved contractual agreements, ensuring adequate levels of data protection unless certain exceptions apply.
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 such data. 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 periods
- 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.
- By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax 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 rights under applicable data protection law
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include You have the right to information about what personal data we process, how and on what basis. You have the right to access your own personal data by way of a subject access request. You have the right to:
Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us directly.
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.
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.
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.
Third Party Links
This 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.
What is a cookie?
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