Personal information will be used within this company by the relevant Personnel according to the principles of applicable data protection legislation (the “DP Legislation”), meaning the General Data Protection Regulation (EU 2016/679)(“GDPR”), the Data Protection Act 1998 (as amended) (“DPA”), the Privacy and Electronic Communications Regulations (2003/2426) (as amended) and the Data Protection (Processing of Sensitive Personal Data) Order 2000.
Owner and Data Controller
Data Manager at email@example.com, 0121 663 0126, 15 Colmore Row, Birmingham B3 2BH
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies and Usage Data.
If you send us an email through the “Contact Us” button part of this Site, we will use the personal data provided to contact you and respond to your query. Save as set out below, we will not intentionally share your personal data with third parties except to the extent necessary to complete the purpose for which you have provided us your personal data for. We will use return email addresses to answer any emails we receive.
By providing us with your e-mail address you consent to our using the e-mail address to provide you with e-mail alert services. If at any time you do not wish to be contacted by us by e-mail please use the link provided on any e-mail sent to you to de-register. Alternatively, write to us at our registered office.
Where required by applicable law, regulatory or governmental requirements, De Novo Advisory Limited will disclose your personal data.
A cookie is simply a bit of data stored on a user’s hard drive which contains information about the user. When the user closes their browser, the cookie will terminate. The cookie we use is essential for parts of this Site to work. You may delete and block all cookies from this Site, but it may mean that parts of this Site may not work. Most web browsers allow some control of most cookies through the browser settings. For further information on cookies please go to www.allaboutcookies.org.
Right of access
If you wish to know what personal information De Novo Advisory Limited holds on you, you may obtain it by contacting us at the address set out below. If it transpires that the information held is inaccurate, we will make the necessary amendments and confirm to you that these changes have been made.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
· Users have given their consent for one or more specific purposes
· Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
· processing is necessary for compliance with a legal obligation to which the Owner is subject;
· processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
· processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
· In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
· Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
· Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
· The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
· Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
· The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics.
· Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
· Contact form
In particular, Users have the right to do the following:
· Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
· Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
· Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
· Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
· Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
· Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
· Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
· Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
· Details about the right to object to processing
· Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
· Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
· To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.