Website Privacy Notice

Website Privacy Notice

15.7.2021

www.cwj.co.uk (our website) is provided by Clarkson Wright & Jakes Ltd (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

The information is written for the benefit of general visitors to the website. If you are a client of ours (or become one, or submit an online enquiry) we process a wider range of privacy-related issues, details of which can be found in our privacy policy which is available on our website.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful.

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Personal data we collect about you
  • How your personal data is collected
  • How and why we use your personal data
  • Marketing
  • Who we share your personal data with
  • How long your personal data will be kept
  • Cookies and other tracking technologies
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us
  • Do you need extra help?

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional services available to you). Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

  • your name, address and contact information, including email address and telephone number and company details
  • location data
  • details of any information, feedback or other matters you give us by phone, email, post or via social media
  • your activities on, and use of, our website
  • your personal or professional interests
  • your professional online presence, e.g. LinkedIn profile
  • information about the services we provide to you
  • information about how you use our website and technology systems

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

  • directly, when you enter or send us information, such as when you contact us (including via email), send us feedback, and
  • indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

To communicate with you, for example: we use contact details such as email address or phone number when responding to enquiries made via online forms and subsequently providing services to you

To take steps at your request before entering into a contract

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

We may collect information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information for internal purposes only. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests or those of a third party, ie to be as efficient as we can.

Protecting the security of systems and data

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us manage our business, eg in relation to our financial performance, client base, product range or other efficiency measures

For our legitimate interests or those of a third party, ie to be as efficient as we can.

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant.

To comply with our legal and regulatory obligations

Marketing our services to existing and former clients

For our legitimate interests or those of a third party, ie to promote our business to existing and former clients

See ‘Marketing’ below for further information

External audits and quality checks.

For our legitimate interests or those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We may use your personal data to send you updates (by email, telephone or post) about our services, including new services.

Where we have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’) we will ask for your consent separately and clearly.

We will only send you marketing emails when you tick the relevant boxes when you complete an online enquiry form or instruct us to act for you.

If you have previously agreed to being contacted in this way, you can opt out of receiving marketing communications at any time by:

  • contacting us at cwj@cwj.co.uk ; or
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts. It may take up to 5 days for this to take place.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers;
  • our banks;
  • external auditors, e.g. in relation to ISO accreditation and the audit of our accounts; and
  • Clarkson Wright & Jakes LLP and Clarkson Wright & Jakes Notaries LLP.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share personal data with:

  • external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, when you enquire about our services and/or register with us to receive our newsletters, we will delete this information after one year unless you become a client or have asked to be put on our mailing list.

Different retention periods apply for different types of personal data. Further details on this are available from the Data Protection Partner, Jill Lawton. She can be contacted by email at jill.lawton@cwj.co.uk

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. These cookies help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, how we use and when we will request your consent before placing them and how to disable them, please see our guide on our use of Cookies.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (eg your full name, address and client or matter reference number) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

  • the Information Commissioner in the UK, and
  • a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us

Individuals in the UK

You can contact us and/or our Data Protection Partner by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Our Data Protection Partner’s contact details

Clarkson Wright & Jakes Ltd
Valiant House, 12 Knoll Rise
Orpington, BR6 0PG
Email: cwj@cwj.co;uk
Tel: 01689 887887

Jill Lawton
Email:  jill.lawton@cwj.co.uk
Tel: 01689 887855

Individuals in the EEA

Individuals within the EEA can contact us direct (see above)

Do you need extra help?

If you would like this policy in another format (for example large print) please contact us (see ‘How to contact us’ above).

15.7.2021