PRIVACY & COOKIES POLICY
Your privacy is very important to us.
INFORMATION WE COLLECT
We obtain information from or about you in the following scenarios:
(i) information you directly give us by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, postal address and phone numbers and information relevant for us to assist you in our capacity as a reputation management firm.
(ii) we may also receive information about you from other publicly available sources. This includes but not limited to content that is publicly available on social media.
You are not required to provide us with any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other categories of information defined as sensitive or special categories of data under applicable data protection laws (“Sensitive Information”) in order to use our services. We do not knowingly solicit or collect, and you should not provide to us, any such Sensitive Information.
The only cookies we use are Google Universal Analytics. These cookies are used to collect information about how visitors use our website. We may use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from the pages they visited.
HOW WE USE AND PROCESS YOUR DATA
Any information that we collect about you will only be used to for the purpose of providing our services to you.
Our legal basis for collecting and using the personal information described in this Policy will depend on the personal information concerned and the specific context in which we collect and use it.
We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so.
Your personal data will be held in confidence and not passed to any company, other than those agreed, without your express permission or unless we are required by law.
We are committed to protect and secure your personal information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to ensure the safety and security of your personal information. This includes using at least industry standard security measures to protect the loss, misuse, and unintended alteration of the personal information under our control.
RETENTION OF YOUR DATA
Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes and in all circumstances, we will only keep your personal data within the timeframes allowed by law and for so long as is necessary to comply with our legal obligations.
TRANSFER OF DATA
We do not as a matter of course transfer your personal information outside of the UK. If we need to transfer personal information to countries outside of the UK and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable data protection laws.
Your right to object, access, correct and delete.
You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity. We may withhold such personal information to the extent permitted by law.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:
- you contest the accuracy of the personal data; processing is unlawful but you oppose erasure;
- we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
UPDATES AND CONTACT
Please let us know if the personal information which we hold about you needs to be corrected or updated.
We may update this Policy from time-to-time by posting a new version on our website. You should check this page occasionally to remain informed.
If you have any questions or requests about this Policy or our treatment of your personal information, please write to us by post at Sanctuary Counsel Limited, 5 – 8 The Sanctuary, London SW1P 3JS.
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.