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Who we are And Some Important Legal Bits

Ricci Solicitors Ltd is a limited liability company registered in England and Wales with registered number 14588440 trading as Ricci & Partners. Its registered office is at Suite 1, Clockhouse, Dogflud Way, Surrey, GU9 7UD. Ricci & Partners is regulated by the Solicitors Regulation Authority SRA 8003763

Our contact details are as follows:

T:  0330 120 1819

E:  info@ricciandpartners.co.uk

A: Suite 1, Clockhouse, Dogflud Way, Surrey, GU9 7UD

In the Policies below we’, ‘us’ or ‘our’ means Ricci & Partners. ‘You’ or ‘your’ means the person accessing or using the Site or its content.

Terms of Use

These terms tell you the rules for using our website www.ricciandpartners.co.uk (Site).

BY USING OUR SITE YOU ACCEPT THESE TERMS  

By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms, you must not use our site.
We recommend that you print a copy of these terms for future reference.

THERE ARE OTHER TERMS THAT MAY APPLY TO YOU  

 
These terms of use refer to the following additional terms, which also apply to your use of our site:
 
• Our Privacy Policy which explains how we process your personal data.
• Our Acceptable Use Policy which sets out the permitted uses and prohibited uses of our site. 
• Our Cookie Policy which sets out information about the cookies on our site.

If you purchase goods or services directly from the site, Terms of Business will apply to the sales. If we provide you with bespoke services Terms of Business and a Client Care Letter will be issued to you.

WE MAY MAKE CHANGES TO THESE TERMS  
 

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on the 1 October 2021.

WE MAY MAKE CHANGES TO OUR SITE  
 
We may update and change our site from time to time to reflect changes to our products or services, our users’ needs and our business priorities and for any other reason. We reserve the right to do so without any notice to you.

WE MAY SUSPEND OR WITHDRAW OUR SITE  
 
Our site is made available free of charge save for members of only content.
 
We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
 
You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

WE MAY TRANSFER THIS AGREEMENT TO SOMEONE ELSE  
 
We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract. Our site is directed to people residing in England & Wales. We do not represent that content available on or through our site is appropriate for use or available in other locations.

YOU MUST KEEP YOUR ACCOUNT DETAILS SAFE  
 
If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures which allow you access to Members Only section of our website, you must treat such information as confidential. You must not disclose it to any third party.
 
We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.
 
If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us by contacting us.

HOW YOU MAY USE MATERIAL ON OUR SITE  
 

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
 
You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.
 
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
 
Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.
 
You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.
 
If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

DO NOT RELY ON INFORMATION ON THIS SITE  
 
The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.
 
Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

WE ARE NOT RESPONSIBLE FOR WEBSITES WE LINK TO  
 
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.
 
We have no control over the contents of those sites or resources.

USER-GENERATED CONTENT IS NOT APPROVED BY US  
 
This website may include information and materials uploaded by other users of the site, including to bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values. We do not anticipate at this stage that there will be user generated content available on our site.

HOW TO COMPLAIN ABOUT CONTENT UPLOADED BY OTHER USERS  
 

If you wish to complain about content uploaded on our site, please contact us.

OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU  
 
We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any products to you, which will be set out in our Terms of Business. 

If you are a business user:
 
• We exclude all implied conditions, warranties, representations or other terms that may apply to our site or any content on it.
• We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
• use of, or inability to use, our site; or
• use of or reliance on any content displayed on our site.
• In particular, we will not be liable for:
• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

If you are a consumer user:
 
• Please note that we only provide our site for business use and we do not knowingly or willing provide services to consumers. As such your use of the site and any of the services that we provide will not be subject to Consumer Rights Act 2015 or Consumer Contract Regulations 2013.


• If defective digital content that we have supplied, damages a device or digital content belonging to you and this is caused by our failure to use reasonable care and skill, we will either repair the damage or pay you compensation. However, we will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge or for damage that was caused by you failing to correctly follow installation instructions or to have in place the minimum system requirements advised by us.

HOW WE MAY USE YOUR PERSONAL INFORMATION  
 
We will only use your personal information as set out in our Privacy Policy.

UPLOADING CONTENT TO OUR SITE  
 
Whenever you make use of a feature that allows you to upload content to our site, or to make contact with other users of our site, you must comply with the content standards set out in our Acceptable Use Policy.

You warrant that any such contribution does comply with those standards, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.
 
Any content you upload to our site will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your content, but you are required to grant us and other users of our site a limited licence to use, store and copy that content and to distribute and make it available to third parties. 
 
We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy.
 
We have the right to remove any posting you make on our site if, in our opinion, your post does not comply with the content standards set out in our Acceptable Use Policy.
 
You are solely responsible for securing and backing up your content.
 
We do not store terrorist content.

WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM  

 
We do not guarantee that our site will be secure or free from bugs or viruses.
 
You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.
 
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

RULES ABOUT LINKING TO OUR SITE  
 
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
 
You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not link with displays any of the trade marks or logos used on our Site without our permission or that of the owner of such trade marks or logos.

You must not establish a link to our site in any website that is not owned by you.
 
Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.
 
We reserve the right to withdraw linking permission without notice.
 
The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use and Terms of Use Policy.
 
If you wish to link to or make any use of content on our site other than that set out above, please contact us.

LAW AND JURISDICTION

These Terms of Use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law and will be subject to England and Wales court jurisdiction.

Acceptable Use

Together with our website terms of use this acceptable use policy (Policy) governs how you may access and use this website and all associated web pages (Site) which is provided by us free of charge. You should read this Policy carefully before using the Site. By using the Site or otherwise indicating your consent, you agree to be bound by this Policy, which supplements our website terms of use. If you do not agree with or accept any part of this Policy you should stop using the Site immediately.

    If you have any questions about this Policy, please contact us using the contact details provided above.

    This acceptable use policy sets out the content standards that apply when you load the content of our site, upload content onto our site, make contact with us using any of the forms found on our site or our third party partners, link to our site, or interact with our site in any other way.

    BY USING OUR SITE YOU ACCEPT THESE TERMS

    By using our site, you confirm that you accept the terms of this policy and that you agree to comply with them.
    If you do not agree to these terms, you must not use our site. We recommend that you print a copy of these terms for future reference.

    THERE ARE OTHER TERMS THAT MAY APPLY TO YOU

    Our Terms of Use also apply to your use of our site.

    WE MAY MAKE CHANGES TO THE TERMS OF THIS POLICY

    We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on the 8 January 2024.

    PROHIBITED USES

    You may use our site only for lawful purposes. You may not use our site:

    – In any way that breaches any applicable local, national or international law or regulation;
    – For any purpose that is prohibited by this Policy or our Terms of Use;
    – In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect or to otherwise commit an act of fraud;
    – For the purpose of harming or attempting to harm minors in any way;
    – To bully, insult, intimidate or humiliate any person;
    – To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards;
    – To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam);
    – To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware;
    – To knowingly transmit any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware;
    – In any manner that disrupts the operation of our Site or business or the website or business of any other entity;
    – To simulate communications from us or another service or entity in order to collect identity information, authentication credentials, or other information (‘phishing’);
    – To promote any unlawful activity (including but not limited to the promotion or sale of any unlawful goods or services);
    – To represent or suggest that we endorse any other business, product or service unless we have separately agreed to do so in writing;
    – To gain unauthorised access to or use of computers, data, systems, accounts or networks; or
    – To attempt to circumvent password or user authentication methods.

    You also agree:

    – Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our Terms of Use;
    – Not to access without authority, interfere with, damage or disrupt any part of our site;
    – Not to access without authority, interfere with, damage or disrupt any equipment or network on which our site is stored;
    – Not to access without authority, interfere with, damage or disrupt any software used in the provision of our site; or
    – Not to access without authority, interfere with, damage or disrupt any equipment or network or software owned or used by any third party.

    INTERACTIVE SERVICES

    We may from time to time provide interactive services on our site, including, without limitation:
    – Chat rooms.
    – Bulletin boards.

    Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

    We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

    The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not fool proof. Minors who are using any interactive service should be made aware of the potential risks to them.

    Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

    CONTENT STANDARDS

    These content standards apply to any and all material which you contribute to our site (Contribution), and to any interactive services associated with it. The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.
    www.justinaricci.com will determine, in its discretion, whether a Contribution breaches the Content Standards.

    A Contribution must:

    – Be accurate (where it states facts);
    – Be genuinely held (where it states opinions);
    – Be provided with the necessary consent of any third party;
    – Be your own original work and lawfully submitted;
    – Comply with the law applicable in England and Wales and in any country from which it is posted.

    A Contribution must not:

    – Be defamatory of any person;
    – Be obscene, offensive, hateful or inflammatory;
    – Bully, insult, intimidate or humiliate;
    – Promote sexually explicit material;
    – Include child sexual abuse material;
    – Promote violence;
    – Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
    – Infringe any copyright, database right or trade mark of any other person;
    – Be likely to deceive any person;
    – Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence;
    – Promote any illegal activity;
    – Be in contempt of court;
    – Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety;
    – Be likely to harass, upset, embarrass, alarm or annoy any other person;
    – Impersonate any person, or misrepresent your identity or affiliation with any person;
    – Give the impression that the Contribution emanates from us, if this is not the case;
    – Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse;
    – Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism;
    – Contain any advertising or promote any services or web links to other sites.

    BREACH OF THIS POLICY

    When we consider that a breach of this acceptable use policy has occurred, we may take such action as we deem appropriate. Failure to comply with this acceptable use policy constitutes a material breach of the Terms of Use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:

    – Immediate, temporary or permanent withdrawal of your right to use our site;
    – Immediate, temporary or permanent removal of any Contribution uploaded by you to our site;
    – Issue of a warning to you;
    – Legal proceedings against you for reimbursement of all costs on an indemnity basis including, but not limited to, reasonable administrative and legal costs resulting from the breach;
    – Further legal action against you;
    – Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law;
    – We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

    LAW AND JURISDICTION

    The terms of this policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. By using this site you agree to the exclusive jurisdiction of the courts of England and Wales.

    Terms of Business

    Different terms of business will apply to different type of transactions. These will be sent to you at the point of instruction together with Privacy Notice intended for clients and our Client Care Letter which will form part of our contract with you.

    Privacy Policy

    Purpose of this privacy policy

    This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us or apply for a position with us.

    This website is not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

    Controller

    Ricci Solicitors Ltd is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy). Our registration number is ZB560475.

    We are not required to appoint a Data Protection Officer. However, our Managing Partner is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Justina Ricci by using the details set out below.

    Contact details

    If you have any questions about this privacy policy or our privacy practices, please contact us. Our details are at the top of this page and can be found here.

    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.

    We hope that Ms Ricci can resolve any query or concern you raise about our use of your information. However, if you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

    Changes to the privacy policy and your duty to inform us of changes

    We keep our privacy policy under regular review.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    Third-party links

    This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

    The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Background Data includes any information that you provide to us that relates to the nature of your enquiry.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

    How is your personal data collected?

    We use different methods to collect data from and about you including through:

    Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.

    Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

    Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.

    Technical Data from the following parties:

    • analytics providers such as Google based outside the EU;
    • advertising networks based inside or outside the EU; and
    • search information providers based inside or outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services Paypal based outside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

    How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you;
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
    • Where we need to comply with a legal obligation.
    • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below

    Purpose/Activity

    Type of data

    Lawful basis for processing including basis of legitimate interest

    To register you as a new client

    (a) Identity

    (b) Contact

    Performance of a contract with you

    To process and deliver your order including:

    (a) Manage payments, fees and charges

    (b) Collect and recover money owed to us

    (a) Identity

    (b) Contact

    (c) Financial

    (d) Transaction

    (e) Marketing and Communications

    (f) Background

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to recover debts due to us)

    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy

    (b) Asking you to leave a review or take a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing and Communications

    (e) Background

    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    To enable you to partake in a prize draw, competition or complete a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (b) Necessary to comply with a legal obligation

    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (f) Technical

    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To make suggestions and recommendations to you about goods or services that may be of interest to you

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Usage

    (e) Profile

    (f) Marketing and Communications

    Necessary for our legitimate interests (to develop our products/services and grow our business)

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  We have established the following personal data control mechanisms:

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

    Third-party marketing

    We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

    Opting out

    You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

    Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    Disclosures of your personal data

    We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

    Internal Third Parties as set out in the Glossary.

    External Third Parties as set out in the Glossary.

    Specific third parties listed in the table Purposes for which we will use your personal data above.

    Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    International Transfers

    We do not transfer your personal data outside the European Economic Area (EEA).

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 
    • Where we use providers based 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.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    Data Security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    Data Retention

    How long will you use my personal data for?

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data and Background) for six years after they cease being customers for tax purposes and to defend legal claims against us.

    In some circumstances you can ask us to delete your data: see your legal rights below for further information.

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    Your Legal Rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw consent.

    If you wish to exercise any of the rights set out above, please contact our DPO.

    No fee usually required

    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 could refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us 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.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Glossary

    LAWFUL BASIS

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    THIRD PARTIES

    Internal Third Parties

    None

    External Third Parties

    Service providers acting as processors based in the EU who provide IT and system administration services and telephone services.

    Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

    HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based [in the United Kingdom who require reporting of processing activities in certain circumstances.

    SRA and any other regulator.

    YOUR LEGAL RIGHTS

    You have the right to:

    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.

    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, though we may need to verify the accuracy of the new data you provide to us.

    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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    If you want us to establish the data’s accuracy.

    Where our use of the data is unlawful but you do not want us to erase it.

    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    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.

    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 advise you if this is the case at the time you withdraw your consent.

    Cookie Policy

    We use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our website, use our Website and purchase any products or services from us. It also allows us to make necessary improvements to create a user-friendly experience for you when you use our Website.

    A cookie is a small data file that is transferred to your device’s hard drive (e.g. your phone or your computer). For example, a cookie could allow us to recognize your browser, while another could store your preferences. It helps our Website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role and without them, using our Website would be a much more frustrating experience.

    This policy explains how and why we use these technologies and the choices you have.

    What cookies we use

    There are two types of cookies used. Session cookies, which will normally expire when you close your browser and Persistent Cookies which will remain on your device after you close your browser and can be used again the next time you access our website.

    The cookies are further categorised into the following:

    • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
    • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality cookies. These cookies are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region) and allows us to provide enhanced, more personalised features. These cookies allow you to optimise your user account and are used to remember the changes you have made to any parts of the Website that you can customise.
    • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

    We may use other technologies with similar functionality to cookies. For details of those please visit our Privacy Policy.

    How we use Cookies

    We use these technologies for a number of purposes, such as:

    • To estimate our audience size and usage pattern;
    • To enable you to use and access our Website;
    • To enable you to book our services or buy our products;
    • To enable you to use our payment facility;
    • To enable, facilitate and streamline the functioning of and your access to our Website;
    • To enable us to recognise you when you return to our Website and speed up your searches;
    • To better understand how you navigate through and interact with our Website, services and products;
    • To allow you to use the Website in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits, save favourites, like products etc. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim;
    • To show you content that is relevant to you and to serve you tailored advertising;
    • To promote our products and services better;
    • To monitor and analyse the performance, operation, and effectiveness of our Website;
    • To enforce legal agreements that govern use of the Website and to monitor any potential breaches of the Terms of Use or Terms of Business;
    • To detect and prevent fraud, trust and safety, and investigations.
    • For purposes of our own customer support, analytics, research, product development, and regulatory compliance.

    Device Information

    We may use device-related information to authenticate users. For example, we may use your IP address, browser information, or other data provided by your browser or device to identify the device being used to access our Website. We may also use these device-related techniques for associating you with different devices that you may use to access our content including for fraud-protection purposes.

    Flash Cookies

    We may use Flash Cookies, also known as Local Stored Objects, and similar technologies to personalise and enhance your online experience. A Flash cookie is a small data file placed on your computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.

    We use Flash cookies to personalise and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website.

    If you disable Flash cookies or other similar technologies, please note that you may not have access to certain content and product features.

    Pixel Tags and Web Beacons

    Pixel tags and web beacons are tiny graphic images that contain unique identifiers and small blocks of code which are placed on website pages, ads, or in our emails. They allow us to determine whether you performed a specific action. When you access these pages, or when you open an email, the pixel tags and web beacons let us know you have accessed the web page or opened the email and allow us to verify any clicks through to links or advertainments within the email. These technologies record your email address, IP address, date, and time associated with each open and click for a campaign. We use this data to establish how the email campaign performed and what actions you took in response to those communications. These tools help us measure response to our communications and improve our Website, our promotions and how we communicate with you.

    The pixel are normally deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should read the email in plain text view or with images disabled.

    Server Logs and Other Technologies

    We collect many different types of information from server logs and other technologies. For example, we collect information about the device you use to access our Website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. For more information on what technical data we collect, please visit our Privacy Policy.

    Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our website and the website you visit after you leave our site. These tools help us improve user experience and deliver our services.

    Third Party Social Plugins

    We may use social plugins provided and operated by third parties, such as Facebook’s, Instagram’s or LinkedIn engagement buttons. As a result of this, you may send to the third party the information that you are viewing on a certain part of our Website. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with our Website to your account with them. Please refer to the third party’s privacy policies to learn more their cookies and how they will process any data that is shared with them. Please note that those third parties may also use other cookies, over which we have no control. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

    Third Party Cookies

    We may also use third party providers to place these technologies on our Website. These third-party providers may use technologies that help us analyse how you use the Website (for example by noting the third-party services from which you have arrived) and market and advertise our services to you on our Website or third-party websites such as Google. They may also help us detect and prevent fraud or conduct risk assessments or collect information about your activities on our Website, other sites or the ads that you have clicked.

    It is important that you understand that those third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on our website and on other websites or online services. Targeting and advertising cookies we use may include Google, and other advertising networks and services we use from time to time. For example, we may use Google Analytics tools. If you do not wish the Google Analytics to use your information, you may install the Google Analytics Opt-Out Browser by clicking here.

    For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu.

    Google Analytics

    Google Analytics is Google’s analytics tool that helps website and app owners to understand how their visitors engage with their properties. It may use a set of cookies to collect information and report site usage statistics without personally identifying individual visitors to Google. In addition to reporting site usage statistics, data collected on Google properties by Google Analytics may also be used, together with some of the advertising cookies described above, to help show more relevant ads on Google properties (like Google Search) and across the web and to measure interactions with the ads you are shown.

    To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into our website and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.

    Siteimprove

    We may use the services provided by Siteimprove to collect statistics about our Website usage. This information is used to improve the user experience on the website by prioritising the fixing of issues relating to content quality, accessibility or SEO.

    The Siteimprove Analytics cookie contains a randomly generated ID used to recognise the browser when a visitor reads a page. IP addresses are anonymised irreversibly before data is made available in Siteimprove. The cookie therefore contains no personal information and is used only for anonymous web analytics (page views, clicks on broken links).

    The information generated by the cookies about your use of the website will be transmitted to and stored by Siteimprove on servers in Denmark. Siteimprove will not transmit this information to third parties.

    Stripe

    Our chosen payments solution provider is Stripe. It uses cookies for the purposes of user authentication, fraud detection, fraud prevention, so you can use the payment facilities on our Website, to monitor its services and support of its advertising strategies. A full disclosure of Stripe’s use of cookies, including persistent cookies, can be found here. The Stripe cookies are an essential part of our payment operations as they allow you to make payments for our products and services. We cannot offer any product or service (the provision of which depends on us receiving a payment from you) if these cookies are disabled by you.

    Mailchimp

    We may use Mailchimp to communicate our offers, updates and promotions to you. Any communication sent to you through MailChimp will automatically contain a web beacon as described above. You can opt out from receiving any mail through MailChimp at any time in accordance to our Privacy Policy and instructions contained within any correspondence you receive from us through MailChimp.

    We may also use MailChimp additional promotional services. If we do so Mailchimp may install a JavaScript tracking snippet (“Snippet”) on our Website. This Snippet allows cookies, pixels, and other technologies to be set on our Website to facilitate the use of certain automations, features and functionality offered by Mailchimp. The specific cookies, pixels, or other technologies that will be set on our Website will depend on the particular add-ons or features that we choose to use at any given time. For more information on what they may be please click here.

    Your Preferences

    Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies by visiting the Help portion of your browser’s toolbar. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of our websites. For more information please select your browser:

    Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

    Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.