6 March 2019
1. Purpose of this Notice
1.1 This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (the GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, all known as Data Protection Legislation.
1.2 . Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. About Us
2.1 Parobus Limited [trading as ?????,] is a company registered in England & Wales under company registration number 11009039, whose registered office is at A Melcombe Regis Court, 59 Weymouth Street, London W1G 8NS.
2.2 For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
3. How we may collect your Personal Data
We obtain personal data about you and your clients and applicants, for example, when:
3.1 you contact us electronically, by telephone or in person in respect of the services we provide;
3.2 you engage us to provide services to you and to your clients and applicants, and also during the proision of those services; or
3.3 from third parties and/or publicly available resources.
4. Information we hold about you
The information we hold about you and your clients and applicants may include the following:
4.1 personal details (such as name, address, contact details, bank details, employment details, financial details) and other information;
4.2 historic details of contacts that we hold in relation to previous matters and provisions of our services;
4.3 details of any services you have received from us;
4.4 our correspondence and communications with you;
4.5 information about any complaints and enquiries you make to us;
4.6 information we receive from other sources, such as publicly available information and information provided by to us by third parties; or
4.7 any other information that relates to your personal and legal affairs and transactions
5. How we use your Personal Data
5.1 We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
5.2 We may process your personal data and that of your clients and applicants for the purposes necessary for the performance of our contract with you and with our other clients. We may also process personal data where you are related to or connected with one of our clients.
5.3 We may process your personal data and that of your clients and applicants for the purposes of our own legitimate interests, provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
5.4 We may process your personal data and that of your clients and applicants for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data, you have the right to withdraw your consent to processing for such specific purposes.
5.5 Please note that we may process your personal data and that of your clients and applicants for more than one lawful basis depending on the specific purpose for which we are using your data.
5.6 We may use your personal data and that of your clients and applicants in order to:
5.6.1 . carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
5.6.2 carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be connected with one of our clients (perhaps as a supplier or otherwise);
5.6.3 provide you with information related to our services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
5.6.4 seek your thoughts and opinions on the services we provide; and
5.6.5 notify you about any changes to our services.
5.7 In some circumstances we may anonymise or pseudonymise personal data, so that it can no longer be associated with you or your client or applicant, in which case we may use it without further notice to you.
5.8 If you refuse to provide us with certain information when requested, we may not be able to supply the services that we may have agreed to supply to you. Additionally, we may be unable to comply with our legal or regulatory obligations.
5.9 We may also process your personal data and that of your clients and applicants without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
5.10 We will only retain your personal data and that of your clients and applicants for as long as is necessary to fulfil the purposes for which it is collected.
5.11 When assessing what retention period is appropriate for your personal data, we take into consideration:
5.11.1 the requirements of our business and the services provided;
5.11.2 any statutory or legal obligations;
5.11.3 the purposes for which we originally collected the personal data;
5.11.4 the lawful grounds on which we based our processing;
5.11.5 the types of personal data we have collected;
5.11.6 the amount and categories of your personal data; and
5.11.7 whether the purpose of the processing could reasonably be fulfilled by other means.
5.12 Where we need to use your personal data or that of your clients or applicants for a reason other than for the purpose for which we collected it, we will only use such personal data where that reason is compatible with the original purpose.
5.13 Should it be necessary to use such personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. Data Sharing
6.1 We will share your personal data with third parties where we are required by law, where it is necessary for the provision of services to you, or where we have another legitimate interest in doing so.
6.2 . The term “third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT, professional advisory services, mortgage providers, administration services, banking services, storage/archiving services, marketing services, and outsourcing services.
6.3 We will ensure that our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
6.4 What about other third parties? We may share your personal data with other third parties to enable us to provide our services to you more efficiently. We may also need to share your personal data with a regulator or otherwise to comply with the law.
7. Transferring Personal Data outside the EEA
7.1 Where it is necessary for your personal data to be forwarded outside the European Economic Area (EEA), we will use appropriate protective measures to protect your personal data.
8. Data Security
8.1 We have put in place commercially reasonable and 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 and that of your clients and applicants on our instructions and they are subject to a duty of confidentiality.
8.2 We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. Rights of Access, Correction, Erasure and Restriction
9.1 Your duty to inform us of changes. It is important that the personal data we hold about you and your clients and applicants is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us.
9.2 Your rights in connection with personal data. Under certain circumstances, by law you have the right to:
9.2.1 Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
9.2.2 Request correction of the personal data that we hold about you.
9.2.3 Request that we 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 exercised your right to object to processing (see below).
9.2.4 Object to the 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
9.2.5 Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
9.2.6 Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
9.3 If you want to exercise any of the above rights, please email the Data Protection Officer with a request to do so.
9.4 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. Right to withdraw Consent
10.1 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data or that of your clients and applicants for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.
10.2 Once we have received notification that you have withdrawn your consent, we will no longer process your personal information or that of your clients and applicants (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. Changes to this Notice
11.1 We will inform you on any changes we may make to our privacy notice in the future.
12.1 If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email or telephone the Data Protection Officer, contact details on website.
12.2 . You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone: 0303-123 1113 (local rate) or 01625-545745; https://ico.org.uk/concerns