Privacy Notice

Website Privacy Policy (GDPR and DPA 2018) (UK)

Introduction

Welcome to the privacy policy for swansealaw.com

swansealaw.com is the website of Swansea Law Chambers Ltd [‘the Company’] a company registered in England & Wales under company number 12419956. Registered Office: Ground Floor, 86 Gower Road, Swansea, SA2 9BZ

The Company is registered with the Information Commissioner’s Office [‘ICO’] for the processing of personal data.

The Company respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how the Company looks after your personal data when you visit the Company’s website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Purpose of this Privacy Policy

This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive emails or pay for a service through his website.

This website is not intended for children. The Company does 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 the Company may provide on specific occasions when he is collecting or processing personal data about you so that you are fully aware of how and why he is using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Comtrol

The Company controls and is responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Company using the details set out below.

Contact Details

If you have any questions about this privacy policy or the Company’s privacy practices, please contact the Company in the following ways:

Email address: info@swansealaw.co.uk

Postal address: Swansea Law Chambers Ltd, 86 Gower Road, Swansea, SA2 9BZ.

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). The Company would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact the Company in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Company of Changes

The Company keeps his privacy policy under regular review. This version was last updated on 25/03/2020.

It is important that the personal data the Company holds about you is accurate and current. Please keep the Company informed if your personal data changes during your relationship with him.

Third Party Links

This website includes 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. The Company does not control these third-party websites and he is not responsible for their privacy statements. When you leave this website, the Company encourages you to read the privacy policy of every website you visit.

The Data The Company Collects 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).

The Company may collect, use, store and transfer different kinds of personal data about you which the Company has 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.

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 me.

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 my website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The Company collects, uses and shares 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, the Company may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if the Company combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, the Company treats the combined data as personal data which will be used in accordance with this privacy policy.

The Company does 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).

If You Fail to Provide Personal Data

Where the Company needs to collect personal data by law, or under the terms of a contract the Company has with you, and you fail to provide that data when requested, the Company may not be able to perform the contract he has or is trying to enter into with you (to provide you with services). In this case, the Company may have to cancel a service you have with him but he will notify you if this is the case at the time.

How is your personal data collected?

The Company uses different methods to collect data from and about you including through:

Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you: apply for services; subscribe to receive emails; request marketing to be sent to you; or give the Company feedback or contact the Company.

Automated technologies or interactions. As you interact with the Company’s website, the Company will automatically collect Technical Data about your equipment, browsing actions and patterns. The Company collects this personal data by using cookies [server logs] and other similar technologies.

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

Technical Data from the following parties: (a) analytics providers including Google and Microsoft, both based outside the EU; (b) advertising networks such as Facebook based outside the EU; and (c) search information providers such as Google and Microsoft both based outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU.

Identity and Contact Data from data brokers or aggregators such as Google and Microsoft both 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 The Company Uses Your Personal Data

The Company will only use your personal data when the law allows him to. Most commonly, the Company will use your personal data in the following circumstances:

Where the Company needs to perform the contract he is about to enter into or has entered into with you.

Where it is necessary for the Company’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where the Company needs to comply with a legal obligation.

Generally, the Company does not rely on consent as a legal basis for processing your personal data, although the Company 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 the Company.

Purposes For Which The Company Will Use Your Personal Data

The Company has set out below a description of all the ways the Company plans to use your personal data, and which of the legal bases the Company reles on to do so. The Company has also identified what its legitimate interests are where appropriate.

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

Activity: To register you as a new customer.

Type of data: Identity; and Contact.

Lawful basis: Performance of a contract with you.

Activity: To process and deliver your order including manage payments, fees and charges; and Collect and recover money owed to me.

Type of data: Identity; Contact; Financial; Transaction; and Marketing & Communications.

Lawful basis: Performance of a contract with you; and Necessary for my legitimate interests (to recover debts due to me).

Activity: To manage the Company’s relationship with you which will include: notifying you about changes to our terms or privacy policy; and asking you to leave a review or take a survey.

Type of data: Identity; Contact; Profile; and Marketing & Communications.

Lawful basis: Performance of a contract with you; Necessary to comply with a legal obligation; and Necessary for the Company’s legitimate interests (to keep the Company’s records updated and to study how customers use his services).

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

Type of data: Identity; Contact; and Technical.

Lawful basis: Necessary for the Company’s legitimate interests (for running its business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and necessary to comply with a legal obligation.

Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising.

Type of data: Identity; Contact; Profile; Usage; Marketing & Communications; and Technical.

Lawful basis: Necessary for the Company’s legitimate interests (to study how customers use my products/services, to develop them, to grow my business and to inform our marketing strategy).

Activity: To use data analytics to improve the Company’s website, products/services, marketing, customer relationships and experiences.

Type of data: Technical; and Usage

Lawful basis: Necessary for our legitimate interests (to define types of customers for the Company’s services, to keep the Company’s website updated and relevant, to develop the Company’s business and to inform the Company’s marketing strategy).

Activity: To make suggestions and recommendations to you about  services that may be of interest to you.

Type of data: Identity; Contact; Technical; Usage; Profile; and Marketing & Communications.

Lawful basis: Necessary for the Company’s legitimate interests (to develop the Company’s services and grow the Company’s business).

Marketing

The Company strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. The Company has established the following personal data control mechanisms:

Promotion Offers

The Company may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what the Company thinks you may want or need, or what may be of interest to you. This is how the Company decides which services and offers may be relevant for you (this is called marketing).

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

Third Party Marketing

The Company will get your express opt-in consent before he shares your personal data with any third party for marketing purposes.

Opting Out

You can ask the Company and/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 the Company in writing at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to the Company as a result of a service purchase, warranty registration, 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 this website uses, please see this website’s cookie policy.

Change of purpose

The Company will only use your personal data for the purposes for which he collected it, unless he reasonably considers that he needs 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 the Company.

If the Company needs to use your personal data for an unrelated purpose, the Company will notify you and he will explain the legal basis which allows him to do so.

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

Disclosure of your personal data required by law

The Company may share your personal data with the parties set out below for the purposes set out above.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

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

The Company requires all third parties to respect the security of your personal data and to treat it in accordance with the law. The Company does 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 his instructions

International transfers

The Company shares your personal data with Microsoft Corporation. This will involve transferring your data outside the European Economic Area (EEA).

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

Where the Company uses certain service providers, the Company may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where the Company uses providers based in the US, the Company 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. For further details, see European Commission: EU-US Privacy Shield.

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

Data Security

The Company has 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, the Company limits 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 my instructions and they are subject to a duty of confidentiality.

The Company has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.

Data Retention

How long will you retain my personal data for?

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

To determine the appropriate retention period for personal data, the Company considers 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 I process your personal data and whether the Company can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law the Company has to keep basic information about its clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.

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

In some circumstances the Company will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case the Company 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.

If you wish to exercise any of the rights set out above please contact the Company using the contact details above.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, the Company may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, the Company could refuse to comply with your request in certain circumstances.

What I May Need From You

The Company may need to request specific information from you to help it 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. The Company may also contact you to ask you for further information in relation to your request to speed up its response.

Time Limit to Respond

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

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of the Company’s business in conducting and managing his business to enable it to give you the best service and the best and most secure experience. The Company makes sure it considers and balances any potential impact on you (both positive and negative) and your rights before it processes your personal data for its legitimate interests. The Company does not use your personal data for activities where our interests are overridden by the impact on you (unless the Company has your consent or are otherwise required or permitted to by law). You can obtain further information about how the Company assesses legitimate interests against any potential impact on you in respect of specific activities by contacting the Company.

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 the Company is subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

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

Professional advisers acting as processors or joint controllers including 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.

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 the Company holds about you and to check that the Company is lawfully processing it.

Request correction of the personal data that the Company holds about you. This enables you to have any incomplete or inaccurate data that the Company holds about you corrected, though the Company may need to verify the accuracy of the new data you provide to it.

Request erasure of your personal data. This enables you to ask the Company to delete or remove personal data where there is no good reason for the Company continuing to process it. You also have the right to ask the Company to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where the Company may have processed your information unlawfully or where the Company is required to erase your personal data to comply with local law. Note, however, that the Company 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 the Company is 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 the Company is processing your personal data for direct marketing purposes. In some cases the Company may demonstrate that he has 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 the Company to suspend the processing of your personal data in the following scenarios:

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

Where the Company’s use of the data is unlawful but you do not want it to erase it.

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

You have objected to the Company’s use of your data but the Company needs to verify whether he has overriding legitimate grounds to use it.

Request the Transfer of Your Personal Data to You or to a Third Party the Company 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.

You can withdraw consent at any time where the Company is 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, the Company may not be able to provide certain products or services to you. The Company will advise you if this is the case at the time you withdraw your consent.