Our website and our services are not intended for children and we do not knowingly collect data relating to children.
1. How we use your personal data
We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, login data, browser type and version, operating system and other technology on the devices you use to access our website, as well as information on the length of your visit, page views, website navigational paths and the frequency and pattern of your website use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our email notifications and newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out here, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
2. Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose your name and email address to our suppliers identified at https://mailchimp.com/ insofar as reasonably necessary for sending you email notifications and/or newsletters.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. International transfers of your personal data
Generally, we process your personal data within the EEA. If we need to transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it as if it were being processed within the EEA.
We and our other group and parent companies have offices and facilities in the US. We may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
4. Retaining and deleting personal data
We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it or to enable us to comply with our legal obligations or enforce our legal rights (the retention period).
At the end of the retention period, we will either delete your data completely, or anonymise it so that, for example, we can aggregate it with other data so that it can be used, without identifying you, for research or statistical purposes.
5. Your legal rights
You have various rights in relation to your personal data, summarised here:
- The right to access: You can 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. For further information, please see the Accessing your data section below.
- The right to rectification: You can 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.
- The right to erasure: You can 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with the law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which, if applicable, we will notify to you.
- The right to restrict processing: You can object to processing of your personal data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to our processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- The right to object to processing: You can request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in any of 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 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.
- The right to data portability: You can 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.
- The right to complain to a supervisory authority: (see below)
- The right to withdraw consent: You can withdraw consent at any time where we are relying 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 products or services to you. We will notify you if this is the case.
6. Accessing your data
Should you wish to access your data, the following information will apply:
- 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 to 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 if you have made a number of requests. In this case, we will notify you and keep you updated.
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
Please contact us in the first instance if you have a concern about how we are dealing with your personal data, though you are entitled to complain at any time to the Information Commissioner’s Office (ICO) at www.ico.org.uk.
10. Our details
This website is owned and operated by KBS Albion. Our contact details are:
Postal Address: 1.03 The Tea Building, 56 Shoreditch High Street, London E1 6JJ
Telephone number: 020 7033 8900
This Policy was last updated on: 25th May 2018