This privacy notice tells you what to expect us to do with your personal information.

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients, for the operation of client or customer accounts and to comply with legal requirements.

• Names and contact details
• Addresses
• Occupation
• Financial data (including income and expenditure)
• Usage data (including information about how you interact with and use our website, products and services)
• Video recordings
• Audio recordings (eg calls)
• Records of meetings and decisions

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients, for the operation of client or customer accounts and to comply with legal requirements are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

• Directly from you
• Suppliers and service providers

How long we keep information

We retain your information for the longest of:

• Our provision of products and services to you or your associates
• The effective period of cover for insurance or indemnity applying to projects or consulting work we conduct for you or your associates
• The life of any contract for services or consulting that may be in effect between us and you or your associates

Who we share information with

Joint data controllers

We have a joint controller relationship with Sennit Ltd. We process your personal information with that joint controller when personnel from each company work with the other on some projects, including due diligence and product development projects.

Data processors

We use a range of software-as-a-service providers such as file backup services, communications providers for messaging and calling, and professional admin products such as accounting systems. We may use these systems to store and handle data, and only use vendors who have their own clear policies on data security, protection, and geographic homing that are in line with our own policies.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO, at:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint

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