HLF PLANNING LTD – PRIVACY NOTICE
HLF Planning Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when:
- you visit our website (regardless of where you visit it from);
- we collect, store or otherwise process your personal data in your capacity as a service provider, a potential employee, consultant or contractor, a potential client or a referrer;
- you are in contact with us on behalf of any other person;
- we otherwise collect, store or use your personal data in order to carry out our business activities (including but not limited to any third parties in any claim or transaction we are instructed to act on).
and tells you about your privacy rights and how the law protects you.
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 and in particular we refer to the separate notice for job applicants, current and former employees, directors and contractors
1. IMPORTANT INFORMATION AND WHO WE ARE
HLF Planning Ltd is the data controller .
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact: David Bevan
Email address: firstname.lastname@example.org
Postal address: 5 Poole Road, Bournemouth, Dorset BH2 5QL
Telephone: 01202 205017
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.
2. 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 we have grouped together follows:
- Identity Data includes name, marital status, title, date of birth, ethnicity, gender, occupation, employment history, job title and function, National Insurance details and documentation relating to your identity.
- Contact Data includes contact addresses, email addresses and telephone numbers.
- Relationship Data includes your family, business and other parties involved in any Matter.
- Matter Data includes details of services we are asked to provide and information related to that matter and relating to any complaints. It also includes details of parties related to those.
- Financial Data includes bank and credit and debit card details, payment details, financial and tax status and related billing information.
- Event Data includes information you provide to us for the purposes of attending meetings and events, including access and dietary requirements.
- Profile Data includes your 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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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 the services you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply or refer others for our services, request marketing to be sent to you or others, enter a competition or survey or give us some feedback or if you offer to provide services to us.
- 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 and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical and Usage Data from analytics providers such as Google, advertising network; and search information providers.
- Identity, Contact, Employment and Matter Data from various parties including referrers, recruitment agencies, other legal service providers, third party advisers including accountants and publicly availably sources such as Companies House and the Electoral Register or your organisation.
- Identity, Contact and Matter Data from various parties including actual or potential clients, referrers, other legal service providers, third party advisers including accountants and publicly availably sources such as Companies House and the Electoral Register.
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 in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or a third party.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
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 or text message.
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 data. Further details are set out below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
· register you as an actual or potential client, third party to a matter, referrer
· manage any suspected, potential or actual conflict of interest compliance with our legal obligations,
· carrying out anti money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws
· identify persons authorised to represent our clients, suppliers or service providers carrying out background checks where permitted
These may include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity, or making records for compliance purposes;
(a) Performance of a contract with you or our client
(b) Necessary to comply with a legal obligation as well as to keep records of our compliance process
(c) Necessary for our legitimate interests
To manage our relationship with you or our clients which may include:
(a) Providing legal or other services or complying with our contractual obligations to you or to our clients
(b) processing payments, accounting, auditing, billing and collection
(c) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you or our clients
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a networking event, prize draw, competition or complete a survey||
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To maintain our accounts and records and to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) including exercising or defending our legal rights, or to comply with court orders or in relation to our insurance||
(a) Necessary for our legitimate interests (for 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)
(b) Necessary to comply with a legal obligation
|To make suggestions and recommendations to you about goods or services that may be of interest to you or to keep you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information), events and initiatives; other promotional activities||
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any company outside HLF Planning Ltd for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our professional services.
We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Service Providers for services such as IT and system administration services, bankers, auditors and insurers who provide consultancy, investigatory, banking, insurance and accounting services, auditors of our business, companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared, couriers, translators or other necessary entities.
- Other parties (including our client) to the matter on which we are instructed including, local authorities, law enforcement authorities, regulators, ombudsmen, government officials and their lawyers or other service providers, courts and tribunals, HM Revenue & Customs, professional advisers including other lawyers, experts, investigators, enquiry agents, estate agents, funeral directors, mediators, arbitrators, and other authorities and parties who provide services to you or our client where this relates to the matter on which we are instructed.
- 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.
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 External Service Providers to use your personal data for their own purposes.
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 need to know.
How long will you keep my personal data for?
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, regulatory, insurance, accounting, reporting requirements and, where required to assert or defend against legal claims. Normally this will be for no longer than 15 years from the conclusion of the matter in respect of which we received the data.
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.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows:
- 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. We encourage you to update us if there are changes so that we can keep your personal data up to date
- 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.
- 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.
- 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 solely 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us with proof of your identity.
9. Updating personal data about you
If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let your usual contact at HLF Planning Ltd know. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
10. Changes to our Privacy Notice
We reserve the right to update and change this Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Notice in the future will be posted on our website and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Notice.
11. Website Disclaimer and Assertion of Copyright
This site is maintained for information purposes only. This site is not intended to be comprehensive and should not be treated as legal advice for any particular purpose. HLF Planning Ltd accepts no responsibility for any loss which may occur in reliance of the information contained on the site. Separate legal advice needs to be obtained for any particular situation.
The contents of the site are governed by copyright and apart from the permission already given on particular pages, written permission from the firm must be obtained before any copying of the contents can be undertaken.