1. Important information and who we are
2. The data we collect about you
3. How we use your personal data
4. Disclosures of your personal data
5. Special Categories of Data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Contact details
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
Intercessio is the controller and responsible for your personal data.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator 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.
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.
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.
- Contact Data includes correspondence address, email address and telephone numbers.
- Financial Data includes bank account details and any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services.
- Transaction Data includes details about payments to and from you and other details of services you have requested from us.
- 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.
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 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 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.
- 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.
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 use information held about you in the following ways:
- To process your request to use our services;
- In the case of a third party whose personal information is provided to us, to process a potential client’s request to use our services;
- To undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
- To comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- To help protect your information and prevent unauthorised access to it;
- To deal with any queries, complaints or problems reported by you;
- To generate statistics relating to use of our website, such as the popularity of certain features or services. We do not use personally identifiable information for these purposes;
- Where, appropriate, to provide you with information about other services we offer that are similar to those that you have already engaged us to provide or have enquired about. You may opt out of receiving this information when we collect your details or at any time by contacting us;
- If required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
- To notify you of changes to our services; and
- To help improve the services we provide to you.
We would like to send you information about services of ours which may be of interest to you. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
You can set your browser settings not to accept cookies and the above websites tell you how to remove cookies from your browser. However, if you do not consent to cookies being placed on your computer or you set your browser not to accept cookies, some of our website features may not function or you may not be able to access parts of our website.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may disclose your information:
- To our IT providers, services providers and agents in order to provide and maintain the provision of the services;
- To our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information in order to advise us;
- To fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
- If required to do so to by law, by any governmental or other regulatory authority or by a court or other authority of competent jurisdiction or any applicable market rules and codes of practice applicable to the circumstances at the time; or
- In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets.
We will not lend or sell your information to third parties.
5. SPECIAL CATEGORIES OF DATA
Data Protection Laws define the following as special categories of data:
- Data revealing your racial or ethnic origins, your political opinions, religious or philosophical beliefs, or any trade union membership you may hold;
- Data concerning your health, your sex life or your sexual orientation.
We will never request this data, however, if supplied, we will process such data in a manner that is permitted under Data Protection Laws. This means that, in some circumstances, we may need you to give us your explicit consent to process this data, which we will request where relevant.
In most circumstances, we will not need you to send us any reports or documents about you that contain any special categories of data about you (for example, letters from your doctors or care providers). You should never send these to us unless we specifically ask you to do so.
6. INTERNATIONAL TRANSFERS
We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (“EEA”) whose Data Protection Laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Data Protection Laws and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
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 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.
8. DATA RETENTION
How long will you use my personal data for?
We retain copies of our customer contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for not less than 5 years after termination or expiry of our contract with you. We retain details of complaints for not less than 5 years from the date of receipt.
In some circumstances you can ask us to delete your data.
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
You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.
- To ask us not to process your personal data for marketing purposes;
- To access personal data held about you and to obtain a copy of it;
- To request the rectification or completion of personal data which are inaccurate or incomplete;
- To restrict or object to the processing of your personal data;
- To request its erasure under certain circumstances;
- In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
- To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
- To lodge a complaint about the way in which your personal data is being used to the ICO.
When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.
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 choose to 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 of receipt. 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. CONTACT DETAILS
Email address: email@example.com
Postal address: 71-75 Shelton Street, London, United Kingdom WC2H 9JQ