- The information that we collect and where we get it from
We collect or obtain your information:
- when you provide it to us (e.g. by contacting us);
- from your use of our website via cookies (such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider); and
We do not collect personally identifiable information about you unless you choose to fill out a form, found on many of the pages of the site or to email us directly.
The personal information that we process includes:
- basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
- contact information, such as your postal address, email address and phone number;
- Financial information, such as payment-related information;
- Identification and background information provided by you or collected as part of our business acceptance processes; and
- Any other information relating to you which you may provide to us.
We do automatically collect certain non-personally identifiable information when you visit our site – such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider.
- How we use the information we collect
We use non-personally identifiable information to analyse site usage (such as aggregated information on the pages visited by our users), which allows us to improve the design and content of our site.
We may do the following with your personal information:
- to respond to your inquiry or form you have completed on various sections of our Website;
- use it to provide legal services;
- use it to engage in marketing and business development activity in relation to our legal services. This may include sending you newsletters, legal updates, marketing communications and other information that may be of interest to you;
- to comply with legal and regulatory obligations that we have to discharge; and
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business.
- Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent– we may (but usually do not) need you consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract– we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest– we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation– we may use your personal information as necessary to comply with applicable law/regulation.
- How we share information with third parties
We do not sell or rent your personal information to third-parties.
We may share your personal information with third parties, only to the extent necessary to run our business, provide a service to you, comply with the law, enforce our legal rights or because you have provided consent.
This may include the following.
- Third party agents/suppliers or contractors, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, website hosting, IT and communications service providers.
- Third parties relevant to the services that we provide.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
- Where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.
- Links to other websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
- Website forms
Any forms which are available on our website are powered by Jotforms also bound by the EU General Data Protection Regulations.
When you fill out a form, the data that you submit will be forwarded to Jotforms and will be collated into an email and sent to us.
The data that you submit via the form will not be stored within this website’s own database or in any of our internal computer systems.
Your data will remain within Jotform’s secure database in the EU for as long as we continue to use Jotform’s services or until you specifically request removal by emailing us.
We consider JotForm to be a third party data processor.
For more information, please see https://www.jotform.com/privacy/
- Transferring your information outside of Europe
We may transfer your personal information outside of the European Economic Area.
If we do transfer your personal data outside the EEA:
- it will be because you have consented or because we have a legal reason to do so; and
- we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
- 16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
- Keeping your information and information security
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
A cookie is a piece of data stored on a user’s hard drive containing information about the user. The information below explains the cookies we use on our website and why we use them:
- Google Analytics cookies: we use these cookies to collect information about how visitors use our website, including details of the site where the visitor has come from and the total number of times a visitor has been to our website. We use the information to improve our website and enhance the experience of its visitors.
You can enable or disable cookies by modifying the settings in your browser. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org.
- Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us. We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
- How to contact us and other important information
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at firstname.lastname@example.org.
Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA220126
Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.
What Information We Collect
We process personal information which you give us:
- As a client to provide you with legal services.
- Whilst servicing your account through our website, in writing or over the phone.
- If you request information or assistance from us.
What personal information we process
- Personal details such as your date of birth, address, National Insurance Number, telephone number and email address; place of residence.
- Identity information such as your passport, driving licence, utility bills or national identity card.
- Credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevent agencies).
- Family, lifestyle, financial and social circumstances.
- Financial details such as your income and information about your bank accounts.
- Employment/self-employment details.
Special Categories of Personal Data
Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Family & Matrimonial or Estate Planning matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.
How we use your Information
We use your information to:
- Provide legal services to you.
- Provide and service your relationship with us.
- Comply with legal obligations for the prevention of financial crime and money laundering.
We will process your information in order to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.
|Providing a service and internal processing|
|To assess your needs and provide you with suitable products and services||Contractual obligation to provide you with, or a proposal including a costs estimate
Where special categories of personal data are processed, these are necessary to assess your needs
|To service and administer your matter including billing||Legitimate interests to provide and manage the service|
|To verify the identity of our clients||To comply with legal obligations to prevent money laundering|
|To confirm, update and improve our client records||To comply with legal obligations in the Data Protection legislation|
|To provide you with any information on the services that you have requested||To meet our contractual obligation to provide information on the services you have requested|
|To manage and develop our relationship with you||Legitimate interest to service your matter and improve our service to you|
|To inform you of services that may be of interest to you, where you have chosen to be made aware of this||With your consent|
|Training and development|
|For training purposes and to improve our service to you||Legitimate interests to improve our services and develop our employees|
|Complying with Legal Obligations|
|To prevent, investigate and prosecute crime, fraud and money laundering||To comply with legal obligations for prevention of financial crime and money laundering|
|For auditing purpose||To comply with our legitimate interest to conduct audits|
|If we are obliged to disclose information by reason of any law, regulation or court order||To comply with legal obligations|
|To transfer information to any entity which may acquire rights in us||Legitimate interests for commercial interests|
|For any other purpose to which you agree.||With your consent|
How we retain your personal information
We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.
Our retention periods are:
|Type of personal Information||Retention Period|
|General personal data which includes your normal personal data, personal identity and personal financial data||7 years after the end of our business relationship with you, or the end of your matter which ever comes later|
|Client Due Diligence Material which includes copies of your Passport, Drivers Licence, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering||7 years after the end of our business relationship with you, or the end of your matter which ever comes later|
|Special categories of personal data||7 years after the end of our relationship with you|
How we share your information
Where necessary or required we share information with:
- Regulatory authorities to comply with our legal obligations.
- Credit reference agencies to check your identity in accordance with our legal obligations.
- Property Search Companies and related service providers to identify any issues that might influence your decision to buy or sell a property.
- Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
- Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
- Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
- Experts and Barristers required to work on your matter.
- Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.
In relation to all of these rights, please write to us at the address below.
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk).
You can contact us by writing to us at VMA Solicitors, Rex House, 4-12 Regent Street, St James’s, London, SW1Y 4PE