This Privacy Policy sets out how we, Sinclair Taylor Management Services, collect, store and use information about you when you use or interact with our website, sinclairtaylor.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 25th May 2018.
For ease of reference, this Privacy Policy is divided in two: a summary privacy policy and the full privacy policy.
If you have any questions about our Privacy Policy, please contact us by sending an email to offstpice@sinclairtaspbotylor.co.uk
Our Details
The data controller in respect of our website is Sinclair Taylor Management Services Limited, Company registration number: 6875402, at registered address of Compass House, Waterside, Hanbury Road, Bromsgrove, Worcestershire B60 4FD. You can contact the data controller by writing to the address above or sending an email to
offstpice@sinclairtaspbotylor.co.uk.
The data protection officer for the data controller is Susan Winnington. You can contact the data protection officer by writing to the address above or sending an email to
complstpiance@sinclairtaspbotylor.co.uk.
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website) and your browser version and operating system.
Our server is located in the UK.
Use of website server log information for IT security purposes
We and our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use essential cookies on our website. For further information on how we use cookies, please see our cookies policy which is available
here.
You can reject some or all of the cookies we use on or via our website by changing your browser settings by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit
allaboutcookies.org or see our
cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is St Neots Computing located in the UK.
Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in the UK.
When you contact us using our contact form, we collect your name, email address, the subject and message.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored within the European Economic Area on our third party email provider’s servers in the UK.
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by us.
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
How we collect or obtain information about you from third parties
We do not collect information about individuals who interact with our website in accordance with this section and the section entitled Disclosure and additional uses of your information.We do not collect information about individuals who interact with our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
We do not receive information about you from third parties except under contract to our clients.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, social media, and websites (including your own website if you have one).
In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as Registered trace agents.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly, and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
Disclosure and additional uses of your information
This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business [and who process your information for us on our behalf].[1] These include the following:[2]
- Telephone provider(s), including. Their privacy policy is available here:
- Email provider(s), including their privacy policy is available here:
- IT service provider(s), including. Their privacy policy is available here:
- Web developer(s), including. Their privacy policy is available here:
- Hosting provider(s), including. Their privacy policy is available here: here:
Our third party service providers are located in the UK.
We disclose your information to other third parties in specific circumstances, as set out below.
Advisors
Occasionally, we obtain advice from and use solicitors. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Occasionally, we obtain advice from and use solicitors. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Our advisors are Somerfield & Co Solicitors. Our advisors are located in Market Street, Lichfield WS13 6JX.
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s):resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period
Server log information: we retain information on our server logs for no longer than 6 weeks.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, after which point we will delete your information.
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
Your subject data will be removed from our records 6 months after payment of the debt in full. Archiving is to allow for any subsequent appeals or questions. At the end of the Archive Period (6 months) all data will be destroyed.
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
-
only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate
-
using secure servers to store your information;
-
verifying the identity of any individual who requests access to information prior to granting them access to information;
-
using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website;
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
All of your information is stored in the following European Economic Area (EEA) countries country: the UK.
Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Sinclair Taylor at Trillium House, First Floor, 32 New Street, St. Neots Cambridgeshire PE19 1AJ or sending an email to
lstpin@sinclairtaspbotylor.co.uk:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available
here
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Other Information
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is unlikely that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to
lstpin@sinclairtaspbotylor.co.uk.
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit
www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. [In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available
here.
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit
gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
