01305 819696 - 07825 611436 - lisa@pharaohlaw.co.uk

Privacy Notice

Privacy Notice : We are committed to protecting and respecting your privacy

Pharaoh Legal Limited is committed to protecting and respecting your privacy.


This Privacy Notice, and any other documents referred to below, contains important information and sets out the basis on which any personal information which we collect about you, that you provide to us or that we have received from a third party source, will be processed by us.  We will tell you what we do with your information and who your information might be shared with.  


If you have any questions about correcting or deleting your personal data then please refer to section 9 Your Legal Rights, below and our Contact details in section 1. 


   

PRIVACY POLICY

  

PHARAOH LEGAL LIMITED respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you become a client, purchase our legal services, or when you otherwise contact us. This policy tells 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.


Sections included in our policy are as follows: 

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY


1. IMPORTANT INFORMATION AND WHO WE ARE 


PURPOSE OF THIS PRIVACY POLICY 

This privacy policy aims to give you information on how PHARAOH LEGAL LIMITED collects and processes your personal data through your use of our website, including any data you may provide through this website when you become a client, when you purchase our legal services, or when you otherwise contact us.

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


CONTROLLER 

PHARAOH LEGAL LIMITED is the controller and responsible for your personal data (collectively referred to “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.


CONTACT DETAILS 

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: PHARAOH LEGAL LIMITED

Email address: lisa@pharaohlaw.co.uk

Postal address: The DPO, Pharaoh Legal Limited, Somerleigh Gate, Somerleigh Road, Dorchester, Dorset, DT1 1TL

Telephone number:  01305 819696

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


CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

We keep our privacy policy under regular review. This version was last reviewed on the 27 April 2019.

It is 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.


THIRD-PARTY LINKS 

This website may include 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


2. THE DATA WE COLLECT 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).

We may collect, use, store and transfer different kinds of personal data about you which we have 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 us.


Technical Data includes your 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 where you provide these


Usage Data includes information about how you use our website, products and services.


Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences where you have provided this data.


We also collect, use and share 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, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


We may collect and process 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). 


However, we will only collect and process Special Categories of Personal Data,

  • With your specific consent
  • Where processing is required by law

Or

  • Where the processing is necessary for the establishment, exercise or bringing or defending of legal claims. 


We do not collect any information about criminal convictions and offences or related data unless legally obliged to do so or in other limited circumstances in connection with legal advice.


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 contract we have or are trying to enter into with you (for example, to provide you with our legal advice and legal services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.


3. 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 Identity, Contact and Financial Data 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;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• give us feedback or contact us.

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 data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources when you use our site and as set out below:

• Technical Data from analytics providers such as Google based outside the United Kingdom, 

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services,

• Identity and Contact Data from data brokers or aggregators 

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

• Data from business partners, sub-contractors, advertising networks, hosting providers, and search information providers. 


4. HOW WE USE YOUR PERSONAL DATA 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you for the provision of legal services.

• 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.

Please consult our GLOSSARY for a meaning of the words LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we 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 us.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have set out below, in a table format, 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 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 below.

  

    


Detail your services

A: 

To register you as a new customer


Type of data : (a) Identity (b) Contact


Lawful basis for processing including basis of legitimate interest : Performance of a contract with you

 

B:  

To comply with contractual obligations including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us


Type of data : 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications


Lawful basis for processing including basis of legitimate interest : 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to   recover debts due to us)

 


C :  

To manage our relationship with you which will   include:

(a) Notifying you about changes to our terms or   privacy policy

(b) Asking you to leave a review or take a survey


Type of data : 

a) Identity

b) Contact

(c) Profile

(d) Marketing and Communications


Lawful basis for processing including basis of legitimate interest : 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to   keep our records updated and to study how customers use our   products/services)

 

D:

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


Type of data : 

(a) Identity

(b) Contact

(c) Technical


Lawful basis for processing including basis of legitimate interest : 

(a) Necessary for our legitimate interests (for   running our business, provision of administration and IT services, network   security, to prevent fraud and in the context of a business reorganisation or   group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

E: 

To deliver relevant website content and   advertisements to you and measure or understand the effectiveness of the   advertising we serve to you


Type of data : 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical


Lawful basis for processing including basis of legitimate interest : Necessary for our legitimate interests (to study   how customers use our products/services, to develop them, to grow our   business and to inform our marketing strategy)

 

F:

To use data analytics to improve our website,   products/services, marketing, customer relationships and experiences


Type of data : 

(a) Technical

(b) Usage


Lawful basis for processing including basis of legitimate interest :

Necessary for our legitimate interests (to define   types of customers for our products and services, to keep our website updated   and relevant, to develop our business and to inform our marketing strategy)

 

G:

To make suggestions and recommendations to you   about goods or services that may be of interest to you


Type of data : 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications


Lawful basis for processing including basis of legitimate interest :

Necessary for our legitimate interests (to   develop our products/services and grow our business)

 



  

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 


PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.


THIRD-PARTY MARKETING 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.


OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase 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. 


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.


5. DISCLOSURES OF YOUR PERSONAL DATA 

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Specific third parties listed in the table “Purposes for which we will use your personal data” above 

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

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do 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 our instructions.


6. INTERNATIONAL TRANSFERS 

Some of our clients or individuals who access our website may be based outside the European Economic Area (EEA) and some external third parties are based outside the EEA so the processing of your personal data will involve a transfer and storage of data outside the EEA.

Whenever we transfer your personal data out of the EEA, other than in 6.1 above, 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, by contacting the DPO at the address above, if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA


7. 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 will notify you, and any applicable regulator, of a breach where we are legally required to do so.


8. DATA RETENTION 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 

We will only retain your personal data for as long as reasonably necessary, depending on the type of data that it is, but no more than twelve years, 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


9. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the following rights:

Request access to your personal data.

This is 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 processing it in accordance with the law.

Request correction of your personal data.

This enables you to have any incomplete or inaccurate data we hold corrected. We will need to verify the accuracy of the new data that you wish to provide to us to be able to change that which we already have.

Request erasure of your personal data.

You can request us to delete or remove your personal data where there is no good reason for us continuing to process it. You can also ask us to delete or to remove you personal data in those circumstances where 

• you have successfully exercised your right to object to processing 

• where we may have processed your information unlawfully 

or 

• where we are required to erase your personal data to comply with our legal obligations

Object to processing of your personal data.

You can object to processing where we are relying upon a legitimate interest (or a third party interest) and you feel this processing impacts upon your fundamental rights and freedoms.  We may however, have compelling and legitimate grounds to process your information which may override your rights as set out in this policy.

Request restriction of processing your personal data.

You can ask us to suspend the processing of your personal data where 

• You want us to establish the data’s accuracy

• You do not want us to erase the data but our use of it is unlawful

• You want us to hold onto the data (even if we no longer require it) because you need it to establish, exercise, bring or defend legal claims

Or

• You have objected to our use of your data but we are checking whether we have overriding legitimate grounds to use it. 

Request transfer of your personal data.

You can request transfer to you, or another party. We will provide it in a structured, commonly used, machine-readable format. 

Right to withdraw consent.

You can withdraw your consent but this means that we may not be able to continue to provide certain products or services to you. Note that this will not affect the withdrawal of processing which has taken place prior to the withdrawal of your consent. 

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


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.


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.


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 a number of requests. In this case, we will notify you and keep you updated.


10. GLOSSARY 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 we are subject to.


THIRD PARTIES 

INTERNAL THIRD PARTIES 

Other companies in the who provide IT and system administration services and undertake reporting.

EXTERNAL THIRD PARTIES 

• Service providers acting as processors 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 who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Other third parties with whom we work for example business partners subcontractors, advertising networks, analytics providers, hosting providers and search information providers) from whom we may also receive information about you.