In this Privacy Notice the terms, ‘we’, ‘us’ and ‘our’ are references to Humphrey and Gray Ltd.
This Privacy Notice sets out the basis on which any personal data we collect from you through our website ( https://humphreyandgray.com ) (Our Site), or that you provide to us via other methods, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it, including:
- • What personal information we collect and when we use it
• Why we use the personal information we collect
• The legal basis upon which we deal with your information
• Data retention
• Disclosure of information
• Third party websites
• Your rights
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
By accessing, browsing or otherwise using Our Site you confirm that you have read and agree to this Privacy Notice. If you do not agree with any part of this Privacy Notice, you should not use Our Site or use our services.
We reserve the right to change the contents of Our Site, including this Privacy Notice at any time, by posting such changes on Our Site. It is your responsibility to familiarise yourself with the Privacy Notice regularly to ensure that you are aware of any changes. Your continued use of Our Site following the posting of any such changes will constitute your acceptance of the revised Privacy Notice.
What personal information we collect and when we use it
We may collect personal information from you in connection with your use of Our Site, including such personal information as:
- • cookie data which relates to your use of Our Site;
• data sent from your browser to our server which may include:
- o the time, date and duration of your visit to Our Site;
o the site from which you have come (the referral URL);
o the pages visited on Our Site; and
o your IP address.
We may also collect personal information voluntarily provided by you to us, for example when you have a query or complaint. In such circumstances, we may collect personal information including your name and contact details, details of your query or complaint and any other information required to enable us to respond to you.
When managing our business relationships with suppliers and other third parties we may need to collect personal information for communication purposes, this is usually limited to business contacts details.
If you are an existing or prospective employee, we will throughout the course of your employment, or when you apply for or enquire about a job, collect personal information including your name, contact details and information relating to your current or historical employment. We have a separate more detailed privacy notice specifically relating to our processing of existing and prospective employee data. Please contact us for further information using the details set out in the Contact section below.
Why we use the personal information we collect
Your information will be used by us in connection with the following purposes:
- • to communicate with you, respond to your questions and/or address any claims or complaints which you may have;
• for business administration and management purposes including human resources, managing relationships with customers, suppliers and other third parties, internal auditing, finance, accounting and investigatory activities;
• to comply with our business, regulatory and legal obligations and respond to requests from public or government authorities;
• to protect our operations,
• to improve your experience when using Our Site; and
• to keep our records up to date.
The legal basis upon which we deal with your information
Wherever we collect or use your personal information, we will make sure we do this for at least one of the following legal reasons:
- • because it is necessary to fulfil a contractual relationship which we have with you;
• because it is necessary to support the legitimate interests of our business to provide you with an efficient service that meets your needs – in all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the section on Your Rights below;
• to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities; or
• where we have obtained a clear consent from you – we will always make it clear when we need your consent and how you can withdraw your consent at any time thereafter.
If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Notice. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings with us.
For further information, please contact us using the details set out in the Contact section below.
Disclosure of information
The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff for the purposes set out in this Privacy Notice or for other purposes approved by you.
We may also disclose your information to the third parties listed below for the following purposes:
- • law enforcement bodies and/or other regulatory entities such as the Information Commissioner’s Office, the police, HMRC and/or local authorities in order to comply with our legal and regulatory obligations;
• third parties we work with as part of providing our services and their associated companies and sub-contractors, including but not limited to IT administrators, entities providing corporate advisory services and our property maintenance suppliers;
• our professional advisers, such as our lawyers and/or auditors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations; and
• third parties as necessary in the event of a claim or dispute relating to the use of our services.
These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.
Third party websites
Our Site may contain links to other websites. We accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by our Privacy Notice.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information:
- • To access personal information
• To rectify / erase personal information
• To restrict the processing of your personal information
• To transfer your personal information
• To object to the processing of personal information
• To object to how we use your personal information for direct marketing purposes
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
• To lodge a complaint with your local supervisory authority
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us using the details in the Contact section of this Privacy Notice. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in the following limited circumstances:
- • where it is no longer needed for the purposes for which it was collected; or
• where you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object (see right to object); or
• where it has been processed unlawfully; or
• to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- • for compliance with a legal obligation; or
• for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict the processing of your personal information, but only where:
- • its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction:
• where we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- • the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we do not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the UK.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority (the contact details for which are set out in the Complaints section of this Privacy Notice) if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Contact Details for the controller of your data and Data Protection officer:
Telephone: 01306 747798
Raise a compliant with the Information Commissioner’s Office about us.
If you wish to do this then go to the following webpage and follow the on screen steps: https://ico.org.uk/concerns/handling
Alternatively the Information Commissioners’ contact details are noted below:
Information Commissioners Office
Wilmslow Telephone: 0303 12 1113
Cheshire, SK9 5AF Email: firstname.lastname@example.org