Welcome to the Cartridges Law’s privacy notice.
Cartridges Law respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA TABLE
- Clients and Matter Data Subjects
- Firm Infrastructure and Administration
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
Purpose of this privacy notice
This privacy notice aims to give you information on how Cartridges Law 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 our newsletter.
This website is not intended for children. However, due to the nature of our work, we may collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Cartridges Law is the controller and responsible for your personal data (collectively referred to as “Cartridges Law”, “we”, “us” or “our” in this privacy notice).
Nicky Mein is the Partner responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Nicky Mein using the details set out below.
Our full details are:
Full name of legal entity: Cartridges Law
Partner: Nicky Mein
Email address: email@example.com
Postal address: 46-47 Cowick Street, St Thomas, Exeter EX41AP
Telephone number: 01392 256854
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 notice and your duty to inform us of changes
This version was last updated on 25 May 2018.
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.
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 notice of every website you visit.
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 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 address, email address and telephone numbers.
- 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 interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
Due to the nature of our work, we may collect Special Categories of Personal Data about you during the course of your matter (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. We may also collect any information about criminal convictions and offences. We do not collect this type of data through our website.
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 services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use our ‘contact us’ page;
- request marketing to be sent to you; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google and Facebook based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services inside and outside the EU.
- Identity and Contact Data from:
- advertising networks such as Cartridges Business Hub and the Michelmores Collaborative Legal Network Southwest based inside the EU; and
- publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Matter Data Subjects. If you are an individual connected to an instruction but you are not our client, we may obtain your Identity, Contact Data and Special Categories of Personal Data during the course of our instruction. Legally privileged information and information which we hold under a duty of confidentiality is exempt from certain data processing principles, data subject rights and reporting requirements. For more information on this contact Nicky Mein.
We may receive personal data about you from various third parties during the course of performing our services.
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.
- 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 or regulatory obligation.
- Where we have your consent to communicate in such a manner with you. You have the right to withdraw consent to marketing at any time by contacting us.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
To view 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 click here.
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).
Your prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers is known as a “soft opt in”. This allows us to send marketing texts or emails if we have obtained your contact details in the course of a sale to you, we are marketing similar products or services, and we gave you an opportunity to opt out of marketing when first collecting the details and in every subsequent message. We have only applied this exception to our former clients and existing clients whose data was collected prior to 25 May 2018. For all other marketing communications, we will be seeking consent through our client care letter.
We will get your express opt-in consent before we share your personal data with any company outside Cartridges Law for marketing purposes.
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 service purchase, service experience or other transactions.
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.
We may have to share your personal data with the parties set out in the table in paragraph 4 above. You will be informed of data sharing to any third party not listed above prior to the event and either your consent will be obtained or the legal basis upon which we rely will be explained to you.
We may also chose 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 notice.
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.
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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, insofar as possible 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.
During the course of business, we accumulate information from both individuals and external organisations. We also generate a wide range of data, which is recorded in documents and records. These documents and records are in several different formats, examples of which include, (but are not limited to) communications such as emails, file notes, attendance notes, press releases and information relating to our clients, our business, our suppliers, representations and partners of the business (in both hard copy and electronic form).
In certain circumstances, it will be necessary to retain specific documents in order to fulfil statutory or regulatory requirements and also to meet justifiable operational needs. We will retain some data and forms of information for longer than others. In line with principle 5 of the Act, information is not sought to be kept longer than is necessary.
We are keen to be transparent and proactive to proactively provide data subjects with transparency on how data will be retained by us and ultimately destroyed – to learn more, view our data retention periods click here. There may be exceptional circumstances which require documents to be kept for either shorter or longer periods. In addition, it should be noted that, in line with the Act and our obligation to implement appropriate physical and technical security measures, the data and information held by us electronically is regularly and periodically backed up. These back-up copies are maintained indefinitely as we have assessed a business need to ensure the consistency and stable framework upon which we operate our business.
We review our data retention procedures annually.
The primary factors that inform decisions on retention are:
- Business need.
- Our ongoing obligations to our clients.
- Services provided to our clients.
- The provision of professional services to maintain our professional conduct requirements.
- Our experience of when retention of information and data is likely to be beneficial to the data subject as relevant to the specific services they seek from us, including acting as an ongoing record keeping source relating to our clients and the matters we undertake on our client’s behalf.
- Legislative and regulatory requirements.
- Informed and express consent of the data subject.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw 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 may 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 may 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.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your data in accordance with your freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, have signified your agreement to such processing of your personal data.
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 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 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 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.