In this Policy, “Deverell Smith”, “we”, “us” and “our” refer to Deverell Smith Limited, registered in England & Wales with registered office at 2nd Floor Cannon Green, 1 Suffolk Lane, London, EC4R 0AT. Our company registration number is 05724877.
For the purpose of the Data Protection Legislation, the data controller is Deverell Smith in respect of any Personal Information that you provide to use or that we otherwise obtain about you.
INFORMATION WE COLLECT FROM YOU
When you engage with us (e.g. by sending us emails or by visiting us or making an enquiry through our Website) we may collect and process the following data about you:
Information you give us by filling in forms on our Website, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Website, subscribe to our service, place a posting on our Website, participate in discussion boards or other social media functions on our Website, communicate via our Website (including communicating with other users), complete surveys, update your personal or company profile and when you report a problem with our Website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description (including, but not limited to, age, academic information and qualifications, work history and other professional information) and photograph.
Information we automatically collect about you with regard to each of your visits to our Website, including the following information:
(i) technical information, including the Internet protocol (IP) address used to connect your computer (or other device) to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
(ii) information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
Some of this information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support our customers/users).
INFORMATION WE RECEIVE FROM OTHER SOURCES
We may receive information from other sources who collect Personal Information from you and pass it on to us (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, social networks and credit reference agencies). Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.
USES MADE OF THE INFORMATION
We will only use Personal Information we hold about you (including information we receive from other sources) in the following ways, depending on the types of information:
to carry out 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, as well as support in respect of those services;
to improve our Website (e.g. to ensure that content is presented in the most effective manner for you and for your computer) and services;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
for our internal business processes; and
where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to let you know about other goods and services we offer that are similar to those that you have already purchased or enquired about, and to inform you about important changes or developments to our services, by
[post, telephone and email].
[From time to time, we may also use your Personal Information to contact you for market research purposes. We may contact you by [email, phone or mail]. This will only happen where you have opted-in to receive such communications.
If you do not want us to use your Personal Information in the ways described in this Policy, please let us know by contacting us email@example.com. You may also opt out of receiving marketing emails from us by following the instructions outlined in any marketing email.
HOW WE SHARE YOUR PERSONAL INFORMATION
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with our suppliers, contractors, third party partners (including any investors we may work with), prospective candidates/clients, and any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
If Deverell Smith enters into a joint venture with, purchases or is sold to or merges with another business entity, or in the event that we sell or buy any business or assets, or substantially all of our assets are acquired by a third party, your Personal Information may be disclosed or transferred to the purchaser, our new business partners or owners or their advisors.
We will also share your contact details with selected third parties if you have consented to receive marketing from such third parties. If you change your mind about being contacted by these third parties for marketing purposes, let us know by contacting us using the details set out below, or contact the third party directly.
We may also share aggregated, anonymised information with advertisers and advertising networks (for example, we may inform them that 500 women aged under 40 have clicked on their advertisements on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
OUR SECURITY AND DATA RETENTION MEASURES, AND ANY TRANSFERS WE MAKE OUTSIDE OF THE EEA
All Personal Information you provide to us is stored on our secure servers in the European Economic Area, and we take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. To the extent that we take any payments from you, these will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
In processing your Personal Information, it may be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA“). It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or other accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, or (b) has agreed (by way of written contract) to provide all protections to your Personal Information as required by the Data Protection Legislation.
ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
You have the right to ask us not to process your Personal Information for marketing or research purposes. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal Information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the contact details set out below.
You have the right to see the Personal Information we hold about you and to ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) transfer any information we hold about you to a specified third party. If you wish to do this, please contact us using the contact details set out below.
Should you have any queries or complaints in relation to how we use your Personal Information, please contact us using the details set out below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Any changes we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy. By continuing to use the Website and making use of our services you agree to the updated Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or services.
Questions, comments and requests regarding this Policy are welcomed and should be addressed firstname.lastname@example.org