Data Protection Officer 

 

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, John Sadler at john@sadleradvisory.com.

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Information Commissioner’s Office

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You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

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Data we process 

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We may collect, use, store and transfer different kinds of personal information about you. 
We have collated these into groups as follows:

 

• Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.

• Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.

• Your financial data includes information such as your bank account and payment card details.

• Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.

• Technical data includes your internet protocol (IP) address, 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.

• Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal information but is not considered personal information in law because it does not reveal your identity.

For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

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Method of personal information collection

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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 or engaging with us by post, phone, email, social media or otherwise. 

• 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 information 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.

• Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources, such as Google, Companies House, or the electoral register.

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Special personal information 

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Special personal information is data 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. It also includes information about criminal convictions and offences.

We do not collect any special personal information about you.

If you do not provide personal information we need

Where we need to collect personal information 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 that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

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The bases on which we process information about you

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The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. Information we process because we have a contractual obligation with you.

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. 

 

Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes

• sell products to you

• provide you with our services

• provide you with suggestions and advice on products, services and how to obtain the most from using our website

 

We process this information on the following bases:

• 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.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

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Information we process with your consent

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Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us john@sadleradvisory.com. However, if you do so, you may not be able to use our website or our services further.

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Information we process for the purposes of legitimate interests

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We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

 

• record-keeping for the proper and necessary administration of our organisation.

• responding to unsolicited communication from you to which we believe you would expect a response

• protecting and asserting the legal rights of any party

• insuring against or obtaining professional advice that is required to manage organisational risk

• protecting your interests where we believe we have a duty to do so

• Information we process because we have a legal obligation

• Sometimes, we must process your information in order to comply with a statutory obligation.

 

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

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COOKIES

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Our website uses 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 and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

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• 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 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).

• 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 also share this information with third parties for this purpose.
   

Please note that third parties may also use cookies, over which we have no control. These named 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:

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• Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information;

• Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website’s functionality; and

• Google Ad Words – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality.

You can use your browser settings to block all cookies (including essential cookies), but you may not be able to access all or parts of our website.

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DISCLOSURES OF YOUR PERSONAL INFORMATION

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We may disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer

• We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006

• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights

• We can exchange information with others to protect against fraud or credit risks.

 

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

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INTERNATIONAL TRANSFERS

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We may transfer your personal information outside of the UK where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented, such as only transferring your personal information to countries that have been deemed to provide an adequate level of protection for personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK. 

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DATA SECURITY

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We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We also limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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DATA RETENTION

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We will only retain your personal information 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 information 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. The appropriate retention period will vary depending on the type of personal information collected. 

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YOUR LEGAL RIGHTS

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Under certain circumstances, you have rights under data protection laws in relation to your personal information: 

• Request access to your personal information.

• Request correction of your personal information.

• Request erasure of your personal information.

• Object to processing of your personal information.

• Request restriction of processing your personal information.

• Request transfer of your personal information.

• Right to withdraw consent.

 

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

You will not have to pay a fee to access your personal information (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances.

We may need you to provide evidence of your identity as a security measure and 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, but it could take 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. 

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