This Privacy Notice was last reviewed in October 2018.
Welcome to the Preiskel & Co LLP’s privacy notice (“Notice”) for our Website, www.preiskel.com. Preiskel & Co respects your privacy and is committed to protecting your personal data. This Notice aims to give you information on how Preiskel & Co collects and processes your personal data through your use of this website, including any data you may provide through this website or contact us, or work with us for legal services.
1. IMPORTANT INFORMATION AND WHO WE ARE
This Notice applies to all clients and/or users of Preiskel & Co’s services and Website. Under current data protection legislation (the General Data Protection Regulation (EU) 2016/679 (“GDPR”)) the data controller is Preiskel & Co LLP and is responsible for your personal data. If you have any questions about this Notice, including any requests to exercise your legal rights, please contact our Head of Compliance using the details set out below.
Our Contact Details
If you have any questions about this Notice or our privacy practices, please contact us:
Full name of legal entity: Preiskel & Co LLP
Solicitors Regulation Authority: 390226
Head of Compliance: email@example.com
Postal address: 4 King’s Bench Walk, Temple, London, EC4Y 7DL, UK
Telephone number: +44 (0)20 7332 5640
You have the right to make a complaint at any time to the Information Commissioner’s Office (the “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 our Head of Compliance in the first instance.
2. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Notice under regular review. Please check back frequently to see any updates or changes to our Privacy Notice. It is also 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.
3. THIRD-PARTY LINKS
4. THE DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data: full name, gender, and title.
- Contact data: phone number, mailing address, email address, and other contact details.
- Basic data: organization, job responsibilities, information about family life (excluding special categories of data) including family, children, hobbies and interests.
- Special categories of data: in limited circumstances, where you have provided us with such information as it is necessary for a specific service we are providing to you: religious or other beliefs, racial or ethnic origin, sexual orientation, health data and details of trade union membership.
- Registration data: Newsletter requests, event/seminar registrations, dietary preferences (excluding special categories of data), subscriptions, and downloads.
- Client service data: Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.
- Marketing data: Data about individual participation in conferences and in-person seminars, credentials, associations, product interests, and preferences.
- Compliance data: Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.
- Device data: Computer Internet Protocol (IP) address, unique device identifiers, cookies and other data linked to a device, and data about usage of our Website.
5. 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 legal services we have or are trying to enter into with you. For example, when you initially engage with our services but you do not provide relevant identification documents that would allow us to comply with anti-money laundering checks (as detailed in our engagement letter), we may refuse to carry out our services to you: in such cases, we will notify you at the time.
6. 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 personal data directly 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 services, subscribe to our publications, access our website, request marketing or other information, give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
7. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will obtain your consent before sending third party direct marketing communications to you via email or text message.
We have set out below 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.
- To provide legal advice and respond to inquiries we use basic data, registration data, client Service data, and device data. Lawful Basis: We need to process your information in this way to perform contracts with our clients or for our legitimate interests.
- To manage our business operations and administer our client relationships we use basic data, special categories of data, registration data, marketing data and client service data. Lawful Basis: This processing is necessary in order to perform our obligations under our contracts with our clients (e.g. issuing and processing invoices) and suppliers (e.g. managing the supply of goods and services to Preiskel & Co) or for our legitimate interests.
- To maintain and improve our Website we use device data. It is necessary for our legitimate interests to monitor how our Website is used, which helps us provide a better service to our Website users.
- To protect the security and effective functioning of our Website and information technology systems we use basic data, registration data, transaction data, and device data. Lawful Basis: It is necessary for our legitimate interests to monitor how our Website is used to detect and prevent fraud, other crimes and the misuse of our Website and also to comply with our legal obligations.
- To provide relevant marketing that may be of interest to you including legal services, legal updates, client conferences or networking events, we use marketing data, basic data, special categories of data, registration data, client service data, and device data. Lawful Basis: It is necessary for our legitimate interests to process this information to provide you with relevant marketing updates and invitations.
- To address compliance and legal obligations, such as checking the identity of new clients and to prevent money laundering and/or fraud we use compliance data, basic data, registration data, transaction data, and device data. This processing is necessary for the purposes of complying with legal requirements to which we are subject.
- To consider individuals for employment and consultancy opportunities and manage on-boarding procedures we use job applicant data and compliance data. The processing is necessary for the purposes of recruitment and for complying with legal obligations to which we are subject.
8. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
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.
9. OPTING OUT
You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data you provided to us regarding your legal services.
10. 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.
11. DISCLOSURES OF YOUR PERSONAL DATA
Internal recipients within Preiskel & Co
Personal data may be shared within Preiskel & Co for the purposes of our legal obligations, preventing fraud and/or improving the security of our or services, improving our services, or because you have given consent. Internally, data may be shared with personnel in our various legal, administrative, IT and technical departments. Preiskel & Co adheres to
External recipients outside Preiskel & Co
Preiskel & Co does not share or sell personal information about clients. However, personal data may be handled on behalf of Preiskel & Co by trusted external service providers. In such cases, Preiskel & Co shall ensure that all of the service partners with whom we do business protect the confidentiality and security of client data.
Preiskel & Co may, for example, buy in services which require the processing of personal data relating to our customers and/or the users of our products and services from:
- service providers who assist and support Preiskel & Co with running our website or other IT services.
- providers of payment services, for cross-checking information when finalising contracts.
- consulting firms providing specialist services to Preiskel & Co (security auditors, legal advisors, accountants etc.).
- Service providers acting as processors based the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, Israel, and Spain 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.
12. INTERNATIONAL TRANSFERS
We are located in London, but our consultants and lawyers work internationally from time to time. This will involve transferring your 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.
- 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.
13. 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.
14. 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.
15. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 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.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
16. 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.
17. 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.
18. 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 several requests. In this case, we will notify you and keep you updated.